MOTION FOR ADMISSION PRO - South Carolina

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STATE OF SOUTH CAROLINA BEFORE THE PUBLIC SERVICE COMMISSION DOCKFT NO. 2012-218-E In the Matter of: South Carolina Electric & Gas Company - ) Application for Increases and Adjustments ) in Electric Rate Schedules and Tariffs and ) Request for Mid-Period Reduction in Base ) Rates for Fuel ) MOTION FOR ADMISSION PRO HAC VICE Wal-Mart Stores East, LP and Sam's East, Inc. (collectively, "Walmart") hereby move the South Carolina Public Service Commission (" Commission" ) to permit Derrick Price Williamson to practice Pro Hac Vice before the Commission in the above-captioned proceeding. Pursuant to Rule 404 (SCACR), Mr. Williamson and counsel of record, Stcphanie U. Roberts, are simultaneously filing a copy of the Verified Application for Admission Pro Hac Vice with the South Carolina Supreme Court, along with the requisite fee. The original of the Vcrificd Application is attached hereto. WHEREFORE, as the provisions of Rule 404 (SCACR) have been met, Walmart respectfully requests that this motion be granted. Respectfully submitted, SPILMAN THOMAS & BATTLE, PLLC By Step ( Mary Kathryn King Spilman Thomas &. Battle, PLLC 110 Oakwood Drive, Suite 500 Winston-Salem, NC 27103 Phone: (336) 631-1062 Fax: (336) 725-4476 Email: [email protected] [email protected]

Transcript of MOTION FOR ADMISSION PRO - South Carolina

Page 1: MOTION FOR ADMISSION PRO - South Carolina

STATE OF SOUTH CAROLINA

BEFORE THE PUBLIC SERVICE COMMISSION

DOCKFT NO. 2012-218-E

In the Matter of:

South Carolina Electric & Gas Company - )Application for Increases and Adjustments )in Electric Rate Schedules and Tariffs and )Request for Mid-Period Reduction in Base )Rates for Fuel )

MOTION FOR ADMISSIONPRO HAC VICE

Wal-Mart Stores East, LP and Sam's East, Inc. (collectively, "Walmart") hereby move the

South Carolina Public Service Commission ("Commission") to permit Derrick Price Williamson to

practice Pro Hac Vice before the Commission in the above-captioned proceeding.

Pursuant to Rule 404 (SCACR), Mr. Williamson and counsel of record, Stcphanie U. Roberts,

are simultaneously filing a copy of the Verified Application for Admission Pro Hac Vice with the

South Carolina Supreme Court, along with the requisite fee. The original of the Vcrificd Application

is attached hereto.

WHEREFORE, as the provisions of Rule 404 (SCACR) have been met, Walmart respectfully

requests that this motion be granted.

Respectfully submitted,

SPILMAN THOMAS & BATTLE, PLLC

ByStep (Mary Kathryn KingSpilman Thomas &. Battle, PLLC110 Oakwood Drive, Suite 500Winston-Salem, NC 27103Phone: (336) 631-1062Fax: (336) 725-4476Email: [email protected]

[email protected]

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Dm rick Price WilliensonHarry A. NaumSpilman Thomas k 13attle, PLLC1100 13ent Creek Houlevard, Suite 101

Mechanicsburg, PA 17050Phone: (717) 795-2740Fax: (717) 795-2743Email: [email protected]

bnaumQaspilmanlaw.corn

Dated: October ~2, 2012

Counsel to Wal-Mart Stores East, LP and Sam's East, Inc.

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STATL'l'OUTI I CAROI.,INA

BEFORE TIIE PUBLIC Sl" RVICE COMMISSION

DOCKET NO. 2012-218-E

In the Matter of:

South Carolina Flectric & Gas Company - )Application for Increases and Adjustments )in Electric Rate Schedules and Tariffs and )Request for Mid-Period Reduction in Base )Rates for Fuel )

VERIFIED APPLICATION FORADMISSION PRO HAC VICE

DERRICK PRICE WILLIAMSON

COMES NOW Derrick Price Williamson, Applicant herein, and respectfully represents the following:

I) Applicant*s residential address is:31 Skyline DriveMechanicsburg, PA 17050

2) Applicant's office address is:

Spilman Thomas 8c Battle, PLLC1100 Bent Creek Boulevard, Suite 101Mechanicsburg, PA 17050

3) Applicant has been retained as a member of the above-named law firm retained by Wal-Mart

Stores East, LP and Sam's East, Inc. (collectively "Walmart") to provide legal representation in

connection with the above matter, now pending before the above-named court of the State of South

Carolina.

4) Since April of 1997, November of 1993, and February of 2002 respectfully, Applicant has

been, and presently is, a member in good standing of the bar of the highest federal and state courts of

the District of Columbia and Pennsylvania, where applicant regularly practices law. Please find

attached related certificates of good standing.

5) Applicant has been admitted to practice before the following courts:

Court:

Supreme Court of Pennsylvania

United States Court of Appeals, District of Columbia Circuit

United States District Court, Middle District of Pennsylvania

Date Admitted:

1993

1997

2002

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Applicant is presently a mcmbcr in good standing to the bars of the courts listed above with no

exceptions.

6) Applicant, is not subject to any suspension of disbarment proceedings, and has not been

formally notified of any complaints pntding before a disciplinary agency, with no exceptions.

Applicant affirms the above statement to be true and correcu

7) Applicant never has had an application for admission i&ro itac vice in this or any other

jurisdiction denied or any pro hac vice admission revoked, with no exceptions.

g) Applicant never has had any certificate or privilege to appear and practice before any

administrative body suspended or revoked, with no exceptions.

9) Local counsel of record associated with Applicant in this case is:

Stephanie U. RobertsSpilman Thomas 8: Battle, PLLC110 Oakwood Drive, Suite 500Winston-Salem, NC 27103Phone: (336) 631-1062Fax: (336) 725-4476Email: sroberts spilmanlaw.corn

10) Applicant agrees to comply with the applicable statutes, laws and rules of'the State of South

Carolina, and will familiarize herself with and comply with the South Carolina Rules of Professional

Conduct. Applicants consents to the juidsdiction ol'he South Carolina courts and Cotnntission on

Lawyer Conduct.

11) Applicant respectfully requests to be admitted to practice before the Public Service

Commission in this case only.

D

D

SP1LMAN THOMAS & BATTLE, PLLCCounsel to Wal-Mart Stores, Inc. and Sant's East, Inc.

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VERIFICATION

)COMMONWEALTH OF PENNSYLVANIA )COUNTY OF CUMBERLAND )

)

I, Derrick Price Williamson, do hereby swear or affirm under the penalty of perjury that I amthe Applicant in the above-captioned matter; that I have read the foregoittg application and know thecontents thereof; and that the contents are tru f ~ ledge cept as to those platters statedon information and belief and that as to those

Subscribed and sworn before me this ~Qit day of October, 2012.

Notary Public

LOCAL COUNSEL CONSENT

I hereby consent, as local counsel of record, to the association of Applicant in this causepursuant to Rules Governing Admission Pro Hac Vice to the South Carolina Bar.

DATED this 8 f day of October, 2012.

Stephanie U. Roberts (SC Bar No.Spilman Thomas k, Battle, PLLC110 Oakwood Drive, Suite 500Winston-Salem, NC 27103Phone: (336) 631-1062Fax: (336) 725-4476Email: [email protected]

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SuIteettte Court of getttts'pfttattia

CERTIFICATE OF GOOD STANDING

Derrick Price Wil1iamson, Esq.

DATE OF ADMISSION

November 30, 1993

The above named attorney was duly admitted to the bar of the Commonwealth ofPennsylvania, and is now a qualified member in good standing.

Witness my hand and official sealDated: October 19, 2012

Appellate Court Clerk

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United States Court of AppealsFOR THE DISTRICT OF COLUMBIA CIRCUIT

Certificate of Good Standin

I, Mark J. Langer, Clerk of the United States Court of Appeals for the District of

Columbia Circuit, certify that DERRICK P. WILLIAMSON was on the 30th day of April,

1997, duly admitted and qualified as an attorney and counselor of the Court of Appeals,

and is now a member of the bar of the Court of Appeals in good standing.

In Testimony Whereof, t have hereunto

subscribed my name and affixed the seal

of the Court, at the City. of,Washington,

this 23 day of October, 2012.

FOR THE COURT:Mark J. Langer Cle

., -r~Mark L. PowstanskiDeputy Clerk!CO

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o Ao lsd (kcv. s/98) ccniliccfc oroood slcodms

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OP PENNSYLVANIA

CERTIFICATE OFGOOD STANDING

Mary E. O'Andrea , Cler1c of this Court,

Certify that Derrick P. Williamson , Bar i-l 69274

was duly admitted to practice in this Court on

2/11/2002, and ls lrl good standingDATE

as a member of the Bar of this Court.

Dated at Harrisburg, PA

LOCA TIO/V

10/19/2012

DAlE

ANIL 4 O'ANlNEA, CLERK

CLERK

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CKRT1FICATF, Or SrRV~Cr.

1 hereby certify that I have served a copy of this application upon the South Carolina SupremeCourt by mail addressed to: South Carolina Supreme Court Office of Bar Admissions, P.O. Box11330, Columbia, SC 29211, accompanied b SouthCarolina Suprcnte Court on this ~9:tt day o

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STATE Ol'OUTII CAROLINA

BEFORE TICE PUBLIC SERVICE COMMISSION

DOCKET NO, 2012-218-E

In the Matter of:

South Carolina Electric & Gas Company - )Application I'r Increases and Adjustments )in Electric Rate Schedules and Tariffs and )Request I'or Mid-Period Reduction in Base )Rates for Fuel )

CERTIFICATE OF SERVICE&

I hereby certify that I have this day served a copy of the foregoing Motion for Admission ProHac Vice and Verified Application for Admission Pro Hac Vice of Derrick Price Williamson upon thefollowing parties to this proceeding via Electronic Mail and First Class Mail:

Mitchell M. Willoughby, Esq.Willoughby &, Hoefer, PAP.O. Box 8416Colinnbia, SC 29202-8416mwillou &hb»& willou &hb hoofer.com

Counselfor Sou(h Carolina Elec(ric»ft Gas Company

K. Chad Burgess, Esq.SCANA Corp.220 Operation Way MC C222Cayce, SC 29033

Counselfor Sou(h Carolina ElectricCh Gas Company

Belton T. Zeigler, Esq.Pope Zeigler, LLCP.O. Box 11509Columbia, SC 29211bzci lcra»ezei ler.com

Counselfor Soutl» Carolina Electric»f&: Gas Company

Ellen M. Evans, Esq.Navy I.itigation Office720 Kennon StreetBuilding 36, Roon» 233Washington Navy Yard, DC 20374-5013ellen.eva&»s(ib av &.mil

Counselfor Depar(ment of(he Navy

Jeffrey Nelson, Esq.Nanette S. Edwards, Esq.Office of Regulatoiy Staff1401 Main Street, Suite 900Columbia, SC 29201

nsedwarAare &staff.sc. ovCounselfor Office ofRegula(ory S(aff

Stephen Suggs, Esq.Susan B. Berkowitz, Esq.SC Appleseed Legal Justice Center1518 Washington StreetColumbia, SC 29201

Scott El 1iott, Esq.Elliott & Elliott1508 Lady StreetColumbia, SC 29201

Counsel fo& Sou(h Carolina EnergyUsers Commi((ee

Counselfor AARP

Frank Knapp, Jr.1717 Gervais StreetColumbia, SC 29201fkna alkna a &enc .com

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H. Mark Hamlet, Esq.Hamlet and Associates, PLLC2601 Irongate Drive, Suite 101Wilmington, NC 28412mltamlet a hamlctandassociates.com

Counselfor Time Warner Cable,Incorporated

Respectfully submitted,

SPILMAN THOMAS & BATTLE, PLLC

ByStep (Mary Kathryn KingSpilman Thomas & Battle, PLLC110 Oakwood Drive, Suite 500Winston-Salem, NC 27103Phone: (336) 631-1062Fax: (336) 725-4476Email: [email protected]

kkingwspilmanlaw.corn

Irn(w

Dated: October~, 2012

Derrick Price Williamson13arry A. NaumSpilman Thomas & Battle, PLLC1100 Bent Creek Boulevard, Suite 101Mechanicsburg, PA 17050Phone: (717) 795-2740Fax: (717) 795-2743Email; [email protected]

[email protected]

Counsel to Wal-Mart Stores East, LP and Sam's East, Inc.