IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LEXINGTON INSURANCE COMPANY,

Plaintiff,

v.

DAVID FORREST, T. BEAUCLERC ROGERS IV,

STANLEY MUNSON, MARTIN FINK, all

individually, and NEW BEGINNINGS

ENTERPRISES LLC, A California Limited Liability

Company, and TARLO LYONS, a partnership,

Defendants.

CIVIL ACTION

NO. 02-CV-4435

(Hon. Anita B. Brody)

DEFENDANT NEW BEGINNINGS ENTERPRISES LLC’S

APPLICATION FOR ADMISSION OF COUNSEL PRO HAC VICE

Defendant New Beginnings Enterprises LLC (“NBE”), by its undersigned

counsel, hereby makes this application, pursuant to Rule 83.5.2 of the Local Rules of Civil

Procedure for the United States District Court for the Eastern District of Pennsylvania, for the

admission pro hac vice of Charles A. Adamek, Esquire, and Beverly Y. Lu, Esquire. In support

of this application, NBE avers as follows:

1. Charles A. Adamek is a partner and Beverly Y. Lu is an associate with the

firm of Lord, Bissell & Brook LLP, at its office located in Los Angeles, California.

2. Mr. Adamek and Ms. Lu are members of good standing of the Bar of the

State of California and the Bars of the United States Court of Appeals for the Ninth Circuit and

the United States District Court for the Central District of California. In addition, Mr. Adamek is

a member in good standing of the Bars of the State of Illinois, the Court of Appeal, California,

the United States Court of Appeals for the Seventh Circuit, and the United States District Courts

for the Northern District of Illinois, the Northern District of California, the Southern District of

California, and the Eastern District of California.

Case 2:02-cv-04435-AB Document 65 Filed 07/14/2004 Page 1 of 7
2

3. Mr. Adamek and Ms. Lu are fully familiar with the facts and legal issues

involved in this case. In addition, Mr. Adamek and Ms. Lu are well experienced in the areas that

form the subject matter of this action.

4. The undersigned counsel will continue as associate counsel as required by

Local Rule 83.5.2(a).

5. Accordingly, NBE hereby files this application and respectfully requests

that the Court enter the accompanying Order, formally admitting Mr. Adamek and Ms. Lu pro

hac vice.

WHEREFORE, defendant New Beginnings Enterprises LLC, respectfully

requests that this Court enter an Order in the form attached hereto admitting Charles A. Adamek

and Beverly Y. Lu as counsel pro hac vice on its behalf for all purposes in connection with the

above-referenced matter.

Respectfully submitted,

AK 2450

Alexander Kerr, I.D. No. 00634

Stephen P. McFate, I.D. No. 80806

McCarter & English, LLP

Mellon Bank Center

1735 Market Street, Suite 700

Philadelphia, PA 19103

215.979.3800

Attorneys for Defendant,

New Beginnings Enterprises LLC

Of Counsel:

Charles A. Adamek

Beverly Y. Lu

Lord, Bissell & Brook LLP

Los Angeles, CA 90071

Dated: July 14, 2004

Case 2:02-cv-04435-AB Document 65 Filed 07/14/2004 Page 2 of 7
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LEXINGTON INSURANCE COMPANY,

Plaintiff,

v.

DAVID FORREST, T. BEAUCLERC ROGERS IV,

STANLEY MUNSON, MARTIN FINK, all

individually, and NEW BEGINNINGS

ENTERPRISES LLC, A California Limited Liability

Company, and TARLO LYONS, a partnership,

Defendants.

CIVIL ACTION

NO. 02-CV-4435

(Hon. Anita B. Brody)

ORDER

AND NOW, this ____ day of ____________, 2004, upon consideration of the

Application for Admission of Counsel Pro Hac Vice of Defendant New Beginnings Enterprises

LLC, it is hereby ORDERED that Charles A. Adamek, Esquire and Beverly Y. Lu, Esquire are

admitted to the practice of law before the United States District Court for the Eastern District of

Pennsylvania, pro hac vice, for all purposes in connection with the above referenced action.

BY THE COURT:

, J.

Case 2:02-cv-04435-AB Document 65 Filed 07/14/2004 Page 3 of 7
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LEXINGTON INSURANCE COMPANY,

Plaintiff,

v.

DAVID FORREST, T. BEAUCLERC ROGERS IV,

STANLEY MUNSON, MARTIN FINK, all

individually, and NEW BEGINNINGS

ENTERPRISES LLC, A California Limited Liability

Company, and TARLO LYONS, a partnership,

Defendants.

CIVIL ACTION

NO. 02-CV-4435

(Hon. Anita B. Brody)

MEMORANDUM OF LAW IN SUPPORT OF

DEFENDANT NEW BEGINNINGS ENTERPRISES LLC’S

APPLICATION FOR ADMISSION OF COUNSEL PRO HAC VICE

As set forth in the foregoing Application, Mr. Adamek and Ms. Lu are members

of good standing of the Bar of the State of California and the Bars of the United States Court of

Appeals for the Ninth Circuit and the United States District Court for the Central District of

California. In addition, Mr. Adamek is a member in good standing of the Bars of the State of

Illinois, the Court of Appeal, California, the United States Court of Appeals for the Seventh

Circuit, and the United States District Courts for the Northern District of Illinois, the Northern

District of California, the Southern District of California, and the Eastern District of California.

Mr. Adamek and Ms. Lu are fully familiar with the facts and legal issues involved in this case.

In addition, Mr. Adamek and Ms. Lu are well experienced in the areas that form the subject

matter of this action. As required by Local Rule 83.5.2(a), the undersigned counsel will continue

as associate counsel.

Case 2:02-cv-04435-AB Document 65 Filed 07/14/2004 Page 4 of 7
2

Accordingly, defendant New Beginnings Enterprises LLC hereby files this

application and respectfully requests that the Court enter the accompanying Order, formally

admitting Mr. Adamek and Ms. Lu pro hac vice.

Respectfully submitted,

AK 2450

Alexander Kerr, I.D. No. 00634

Stephen P. McFate, I.D. No. 80806

McCarter & English, LLP

Mellon Bank Center

1735 Market Street, Suite 700

Philadelphia, PA 19103

215.979.3800

Attorneys for Defendant,

New Beginnings Enterprises LLC

Of Counsel:

Charles A. Adamek

Beverly Y. Lu

Lord, Bissell & Brook LLP

Los Angeles, CA 90071

Dated: July 14, 2004

Case 2:02-cv-04435-AB Document 65 Filed 07/14/2004 Page 5 of 7
CERTIFICATE OF SERVICE

I, Alexander Kerr, hereby certify that on this 14th day of July, 2004, I caused a

true copy of the foregoing Application for Admission of Counsel Pro Hac Vice to be served by

United States first class mail, postage prepaid, upon the following counsel:

Jeffrey R. Lerman, Esquire

Montgomery, McCracken, Walker & Rhoads, LLP

123 South Broad Street

Avenue of the Arts

28

th

Floor

Philadelphia, PA 19109

Edward P. Krugman, Esquire

Cahill Gordon & Reindel LLP

80 Pine Street

New York, NY 10005

Edward M. Dunham, Jr., Esquire

Duane Morris LLP

Suite 4200

One Liberty Place

Philadelphia, PA 19103

James J. Rohn, Esquire

Conrad O’Brien Gellman & Rohn, P.C.

16

th

Floor

1515 Market Street

Philadelphia, PA 19102

David L. Pennington, Esquire

Harvey, Pennington, Cabot, Griffith & Renneisen, Ltd.

11 Penn Center

29

th

Floor

1835 Market Street

Philadelphia, PA 19103

Case 2:02-cv-04435-AB Document 65 Filed 07/14/2004 Page 6 of 7
2

Neil G. Epstein, Esquire

Eckert, Seamans, Cherin & Mellott, LLC

9

th

Floor

1515 Market Street

Philadelphia, PA 19102

AK 2450

Alexander Kerr

PH1: 482681.01

Case 2:02-cv-04435-AB Document 65 Filed 07/14/2004 Page 7 of 7