LIBERI v BELCHER, et al. (N.D. TX) - 180.0 - Application for Admission Pro Hac Vice with Cert. of...

8/6/2019 LIBERI v BELCHER, et al. (N.D. TX) - 180.0 - Application for Admission Pro Hac Vice with Cert. of Good Standing for …

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Philip J. Berg, Esquire Application for pro hac vice Admission

District Court for the Northern District of Texas, Amarillo Division. In addition,

Applicant has been Counsel for the Plaintiffs since the filing of this case on May 4,

2009 in the Commonwealth of Pennsylvania. Counsel is very familiar with the

case at hand and is willing and ready to continue his representation of the Plaintiffs

in the Northern District of Texas, Amarillo Division.

4. Applicant is a member in good standing of the bar of the highest

Court in the Commonwealth of Pennsylvania, where Applicant regularly practices

law. Applicant’s bar number is 09867 and was admitted to practice law in the

Commonwealth of Pennsylvania, November 18, 1971. Applicant has attached

hereto as EXHIBIT “A” his letter of good standing from the Commonwealth of

Pennsylvania Supreme Court.

5. Applicant has also been admitted to practice before the following

Courts:

a. U.S. District Court, Eastern District of PA December 12, 1972

b. U.S. Court of Appeals for the Third Circuit 1983

c. U.S. Supreme Court August 2, 1996

6. Applicant has never involuntarily lost, temporarily or permanently,

the right to practice before any Court or tribunal, or resigned in lieu of discipline.

7. Applicant has never been subject to grievance proceedings or

involuntary removal proceedings – regardless of outcome – while a member of the

Case 2:11-cv-00090-J Document 180 Filed 06/10/11 of 6 PageID 3939



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bar of any state or Federal Court except for a complaint filed against him in the

Commonwealth of Pennsylvania by an unhappy client as a result of her 2006 Case.

8. Applicant has not been charged, arrested or convicted of a criminal

offense or offenses.

9. Applicant has not filed for pro hac vice admission in the United States

District Court, Northern District of Texas during the past three (3) years.

10. Applicant has not found local counsel, which satisfies this Court’s

Local Rules of being within fifty [50] miles of the Amarillo Courthouse, to sponsor

him, and therefore, Applicant is requesting a Waiver of the Requirement for Local

Counsel pursuant to this Court’s Local Rule 83.10(a). Applicant has been

litigating the within case since it was filed on May 4, 2009 in the U.S. District

Court, Eastern District of Pennsylvania and is very familiar with the events to date.

Due to the size of the case, it would take new counsel quite some time to

familiarize themselves with the purpose of the suit and events which have occurred

to date, which would delay the proceedings.

11. Moreover, Applicant is Plaintiffs choice of counsel. Currently, in the

California portion of this Case, Applicant is temporarily admitted pro hac vice to

continue representing the Plaintiffs.

12. Applicant has read Dondi Properties Corp. v. Commerce Savs. &

Loan Ass’n, 121 F.R.D. 284 (N.D. Tex. 1988) (en banc), and the Local Civil Rules




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of this Court and will comply with the standards of practice adopted in Dondi and

with the Local Civil Rules.

13. Applicant respectfully requests to be admitted to practice in the

United States District Court for the Northern District of Texas for this cause only.

Applicant certifies that a true and correct copy of this document has been served

upon each attorney of record or pro se party and the original upon the Clerk of

Court, accompanied by a $25.00 filing fee on this 9th day of June, 2011.

Respectfully submitted,

Dated: June 10, 2011 /s/ Philip J. Berg

PHILIP J. BERG, ESQUIRE, Applicant555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531PA Identification No. 09867(610) 825-3134




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EXHIBIT “A”




Case 2:11-cv-00090-J Document 180-1 Filed 06/10/11 Page 1 of 1 PageID 3944



Law Offices of:PHILIP J. BERG, ESQUIREIdentification No. 09867555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531Ph: (610) 825-3134 Applicant for pro hac vice Admission

U.S. DISTRICT COURT, NORTHERN DISTRICT OF TEXASAMARILLO DIVISION

_____________________________________________ LISA LIBERI, et al,

Plaintiffs,vs.

LINDA SUE BELCHER, et al,

Defendants.

:::::::::

CIVIL ACTION

Case No. 2:11-cv-00090-J

Honorable Mary Lou Robinson

CERTIFICATE OF SERVICE

I, Philip J. Berg, Esquire, hereby certify that a copy of my Application for

pro hac vice Admission was served this 10th day of June, 2011, upon the following

Defendants by U.S.P.S. mail with postage fully prepaid.

Edgar HaleCaren Hale

Plains Radio Network, Inc.KPRN

Bar H Farms1404 Bowie Street

Wellington, Texas 79095

Linda Sue Belcher

201 Paris StreetCastroville, TX 78009

/s/ Philip J. Berg

PHILIP J. BERG, ESQUIRE

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Philip J. Berg, Esquire Application for pro hac vice Admission Certificate of Service

Case 2:11-cv-00090-J Document 180-2 Filed 06/10/11 Page 1 of 1 PageID 3945

LIBERI v BELCHER, et al. (N.D. TX) - 180.0 - Application for Admission Pro Hac Vice with Cert. of...

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