IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LEXINGTON INSURANCE COMPANY,

Plaintiff, Civil Action No.

02-CV-4435

v.

DAVID FORREST and T. BEAUCLERC

ROGERS IV,

Defendants.

ORDER ADMITTING EDWARD P. KRUGMAN,

IRA J. DEMBROW AND SCOTT M. MORY

PRO HAC VICE

And now, this ____ day of______, 2002, upon consideration of the Motion of

Lexington Insurance Company for Admission of Edward P. Krugman, Ira J. Dembrow and

Scott M. Mory Pro Hac Vice, and any response thereto, it is hereby ordered that the Motion is

granted, and that Mr. Krugman, Mr. Dembrow and Mr. Mory are admitted pro hac vice to

represent Lexington Insurance Company in this action and are permitted to participate actively in

the conduct of all pretrial, trial and post-trial proceedings in this action.

BY THE COURT:

Anita B. Brody, U.S.D.J.

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Case 2:02-cv-04435-AB Document 4 Filed 08/30/2002 Page 1 of 8
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LEXINGTON INSURANCE COMPANY,

Plaintiff, Civil Action No.

02-CV-4435

v.

DAVID FORREST and T. BEAUCLERC

ROGERS IV,

Defendants.

MOTION OF LEXINGTON INSURANCE COMPANY

FOR ADMISSION OF EDWARD P. KRUGMAN,

IRA J. DEMBROW AND SCOTT M. MORY

PRO HACVICE

The undersigned counsel for plaintiff, Lexington Insurance Company ("Lexington"),

being a member in good standing of the bar of this Court, hereby moves this Court to admit

Edward P. Krugman, Ira J. Dembrow and Scott M. Morypro hac vice, and in support of said

motion states as follows:

1. Edward P. Krugman is a member of the law firm of Cahill Gordon & Reindel,

with an address, telephone number and facsimile number as follows:

Edward P. Krugman, Esquire

Cahill Gordon & Reindel

80 Pine Street

New York, NY 10005

(212) 701-3000 (telephone)

(212) 269-5420 (fax)

2. Mr. Krugman is admitted to practice before and is in good standing with the

following courts: (a) all state courts in New York; (b) the United States District Court for the

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Case 2:02-cv-04435-AB Document 4 Filed 08/30/2002 Page 2 of 8
Southern District of New York; (c) the United States District Court for the Eastern District of

New York; (d) the United States Court of Appeals for the Second Circuit; (e) the United States

Court of Appeals for the Ninth Circuit; and (f) the United States Supreme Court.

3. Mr. Krugman has never been disciplined, suspended or disbarred, and there are no

disciplinary proceedings against him in any jurisdiction.

4. Mr. Krugman has particular knowledge regarding the facts and law in the abovecaptioned action as a result of his long-term representation ofLexington, and Lexington has

requested that he represent it in this action.

5. If Mr. Krugman is admitted pro hac vice in this matter, the undersigned will

remain counsel of record.

6. Attached hereto as Exhibit "A" is a Certification of Edward P. Krugman in

Support of Motion for Admission Pro Hac Vice.

7. Ira J. Dembrow is an associate of the law firm ofCahill Gordon & Reindel, with

an address, telephone number and facsimile number as follows:

Ira J. Dembrow, Esquire

Cahill Gordon & Reindel

80 Pine Street

New York, NY 10005

(212) 701-3000 (telephone)

(212) 269-5420 (fax)

8. Mr. Dembrow is admitted to practice before and is in good standing with the

following courts: (a) all state courts in New York; (b) the United States District Court for the

Southern District of New York; (c) the United States District Court for the Eastern District of

New York; and (d) the United States Court of Appeals for the Second Circuit.

9. Mr. Dembrow has never been disciplined, suspended or disbarred, and there are

no disciplinary proceedings against him in any jurisdiction.

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Case 2:02-cv-04435-AB Document 4 Filed 08/30/2002 Page 3 of 8
10. Mr. Dembrow has particular knowledge regarding the facts and law in the abovecaptioned action as a result of his long-term representation ofLexington, and Lexington has

requested that he represent it in this action.

11. If Mr. Dembrow is admitted pro hac vice in this matter, the undersigned will

remain counsel of record.

12. Attached hereto as Exhibit "B" is a Certification of Ira J. Dembrow in Support of

Motion for Admission Pro Hac Vice.

13. Scott M. Mory is an associate of the law firm ofCahill Gordon & Reindel, with

an address, telephone number and facsimile number as follows:

Scott M. Mory, Esquire

Cahill Gordon & Reindel

80 Pine Street

New York, NY 10005

(212) 701-3000 (telephone)

(212) 269-5420 (fax)

14. Mr. Mory is admitted to practice before and is in good standing with the

following courts: (a) all state courts in New York and New Jersey; (b) all local courts in the

District of Columbia; (c) the United States District Court for the Southern District of New York;

(d) the United States District Court for the Eastern District of New York; and (e) the United

States District Court for the District of Columbia.

15. Mr. Mory has never been disciplined, suspended or disbarred, and there are no

disciplinary proceedings against him in any jurisdiction.

16. Mr. Mory has particular knowledge regarding the facts and law in the abovecaptioned action as a result of his representation ofLexington, and Lexington has requested that

he represent it in this action.

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Case 2:02-cv-04435-AB Document 4 Filed 08/30/2002 Page 4 of 8
17. If Mr. Mory is admitted pro hac vice in this matter, the undersigned will remain

counsel of record.

18. Attached hereto as Exhibit "C" is a Certification of Scott M. Mory in Support of

Motion for Admission Pro Hac Vice.

WHEREFORE, plaintiff, Lexington Insurance Company, respectfully requests that this

Court grant the Motion for Admission of Edward P. Krugman, Ira J. Dembrow and Scott M.

Mory Pro Hac Vice and permit Mr. Krugman, Mr. Dembrow and Mr. Mory to participate

actively in the conduct of all pretrial, trial and post-trial proceedings in this action.

Jeffrey R. Lerman

Glenn F. Rosenblum

Montgomery, McCracken, Walker & Rhoads, LLP

123 South Broad Street

Philadelphia, PA 19109

(215) 772-1500

Attorneys for Plaintiff,

Lexington Insurance Company

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Case 2:02-cv-04435-AB Document 4 Filed 08/30/2002 Page 5 of 8
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LEXINGTON INSURANCE COMPANY,

Plaintiff, Civil Action No.

02-CV-4435

v.

DAVID FORREST and T. BEAUCLERC

ROGERS IV,

Defendants.

MEMORANDUM OF LAW IN SUPPORT OF

MOTION OF LEXINGTON INSURANCE COMPANY FOR

ADMISSION OF EDWARD P. KRUGMAN,

IRA J. DEMBROW AND SCOTT M. MORY

PRO HACVICE

Plaintiff, Lexington Insurance Company ("Lexington"), pursuant to Local Civil Rule

83.5.2, moves for admission of Edward P. Krugman, Ira J. Dembrow and Scott M. Morypro hac

vice.

As set forth in the foregoing motion and attached certifications, each of the above-named

attorneys is a member in good standing with courts of other jurisdictions. Each has particular

knowledge regarding the facts and law in the above-captioned action as a result of his

representation of Lexington, and Lexington has requested that the above-named attorneys

represent it in this action.

If admitted pro hac vice in this matter, Mr. Krugman, Mr. Dembrow and Mr. Mory will

have as associate counsel of record a member of the bar of this Court upon whom all pleadings,

motions, notices and other papers can be served conformably to the Federal Rules of Civil

Procedure and the rules of this Court.

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Case 2:02-cv-04435-AB Document 4 Filed 08/30/2002 Page 6 of 8
Accordingly, Lexington requests that the Motion for Admission of Counsel Pro Hac Vice

be granted.

Respectfully submitted,

Jeffrey R. Lerman

Glenn F. Rosenblum

Montgomery, McCracken, Walker & Rhoads, LLP

123 South Broad Street

Philadelphia, PA 19109

(215)772-1500

Attorneys for Plaintiff,

Lexington Insurance Company

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Case 2:02-cv-04435-AB Document 4 Filed 08/30/2002 Page 7 of 8
CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing Motion for Admission of

Edward P. Krugman, Ira J. Dembrow and Scott M. Mory Pro Hac Vice was served this date

upon the following by U.S. mail, first class, postage prepaid:

Nicholas M. Centrella, Esquire

Conrad, O'Brien, Gellman & Rohn, P.C.

16th Floor

1515 Market Street

Philadelphia, PA 19102-1916

Attorney for Defendant T. Beauclerc Rogers IV

I hereby certify that a true and correct copy of the foregoing Motion for Admission of

Edward P. Krugman, Ira J. Dembrow and Scott M. Mory Pro Hac Vice was served this date

upon the following by International Registered Mail and by Federal Express International

Priority:

Mr. David Forrest

Fletland Mill House

Near Baston

Lincolnshire

PE6 9NS

ENGLAND

Date:

Jeffrey R. Lerman

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