Clay et al v. Bank of America, National Association et al

MOTION for attorney Bruce S. Luckman to Appear Pro Hac Vice

W.D. Pa.November 18, 2010

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA KEVIN & CRYSANNE CLAY, Plaintiffs, v. BANK OF AMERICA, N.A., et al., Defendants. ) ) ) ) ) ) ) ) ) ) C.A. No: 10-0986 MOTION FOR ADMISSION PRO HACE VICE OF BRUCE S. LUCKMAN, ESQ. THE UNDERSIGNED, Timothy P. Creech, pursuant to Local Rule of Civil Procedure 83.2(B), and as a member of the Bar of the United States District Court for the Western District of Pennsylvania, respectfully moves that Bruce S. Luckman, an attorney with the law firm of Kogan, Trichon & Wertheimer, PC, 1818 Market Street, 30th Floor, Philadelphia, Pennsylvania, 9103, be admitted to appear and practice in this Court in this case as counsel pro hac vice for Defendant Trans Union LLC (“Trans Union”). In support of this motion, I state: 1. Bruce S. Luckman is a shareholder in the law firm Kogan, Trichon & Wertheimer, P.C., located at 1818 Market Street, 30th Floor, Philadelphia, PA 19103. Mr. Luckman is a resident of the Commonwealth of Pennsylvania, and a member in good standing of, inter alia, the Bars of the Supreme Court of Pennsylvania, of the United States District Courts for the Eastern and Middle Districts of Pennsylvania, and of the United States Court of Appeals for the Third Circuit. See, Declaration of Bruce S. Luckman attached as Exhibit “A”. 2. Mr. Luckman is a member of the bar in good standing in every jurisdiction in which he has been admitted to practice. Case 2:10-cv-00986-NBF -LPL Document 27 Filed 11/18/10 Page 1 of 5 3. There are no disciplinary proceedings pending against Mr. Luckman in any jurisdiction in which he is admitted to practice. 4. Mr. Luckman has certified that he has read, knows, and understands the local rules of the United States District Court for the Western District of Pennsylvania. WHEREFORE, Trans Union respectfully requests that this Court enter an Order admitting Bruce S. Luckman, pro hac vice in this action. Respectfully submitted, KOGAN, TRICHON & WERTHEIMER, P.C. /s/ Timothy P. Creech TIMOTHY P. CREECH 1818 Market St., 30th Floor Philadelphia, PA 19103 (215) 575-7618; Fax: (215) 575-7688 Email: tcreech@ktwlaw.com Counsel for Defendant, Trans Union LLC DATED: November 18, 2010 Case 2:10-cv-00986-NBF -LPL Document 27 Filed 11/18/10 Page 2 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA KEVIN CLAY, et ux., Plaintiffs, v. BANK OF AMERICA, N.A., et al., Defendants. ) ) ) ) ) ) ) ) ) ) C.A. No: 10-0986 CERTIFICATE OF SERVICE TIMOTHY P. CREECH, Esq., hereby certifies that he caused a true and correct copy of the foregoing Trans Union LLC’s Motion for Admission Pro Hac Vice of Attorney Bruce S. Luckman to be sent on this date, via the Court’s ECF Notice System, to the following: James M. Pietz, Esq. Pietz Law Office 304 Ross St., Suite 700 Pittsburgh, PA 15219 (412) 288-4333 Fax: (412) 288-4334 Email: jpietz@jpietzlaw.com Counsel for Plaintiff Jennifer G. Betts, Esq. Jones Day 500 Grant Street One Mellon Center, Suite 4500 Pittsburgh, PA 15219 412-394-7937; Fax: 412-394-7959 Email: jgbetts@jonesday.com Counsel for Experian Information Solutions, Inc. Leonard A. Bennett, Esq. Consumer Litigation Associates 12515 Warwick Boulevard, Suite 100 Newport News, VA 23606 (757) 930-3660; Fax: (757) 930-3662 Email: lenbennett@clalegal.com Counsel for Plaintiff /s/ Timothy P. Creech TIMOTHY P. CREECH DATED: November 18, 2010 Case 2:10-cv-00986-NBF -LPL Document 27 Filed 11/18/10 Page 3 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA KEVIN & CRYSANNE CLAY, Plaintiffs, v. BANK OF AMERICA, N.A., Defendants. ) ) ) ) ) ) ) ) ) ) C.A. No: 10-0986 ORDER AND NOW this day of , 2010 upon review of the foregoing Motion For Admission Of Bruce S. Luckman, Esq. To appear pro hac vice, it is hereby ORDERED, ADJUDGED, AND DECREED that Defendant’s Motion be and the same hereby is GRANTED. __ J. Case 2:10-cv-00986-NBF -LPL Document 27 Filed 11/18/10 Page 4 of 5 CERTIFICATE OF BRUCE S. LUCKMAN, ESQUIRE IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE I, Bruce S. Luckman, hereby certify that: 1. I am a shareholder in the law firm of Kogan, Trichon & Wertheimer, PC, located at 1818 Market Street, 30th Floor, Philadelphia, PA 19103. 2. I am admitted to practice before, and am a member in good standing of the bars of Supreme Courts of Pennsylvania and Connecticut, of the United States District Courts for the Eastern and Middle Districts of Pennsylvania, and of the United States Court of Appeals for the Third Circuit. 3. I have not been censured, suspended, disciplined or disbarred by any court. In addition, no disciplinary action, contempt, or other proceeding is pending before any court. 4. I am regional counsel for Trans Union LLC and, for more than fifteen (15) years, I have represented Trans Union in matters arising under the federal Fair Credit Reporting Act, 15 U.S.C. §1681, et seq., such as the instant action. I am wholly familiar with the above-captioned action. 5. I have read and understand the local rules of the United States District Court for the Western District of Pennsylvania and agree to comply with those rules. I declare under penalty of perjury of the laws of the United States that the foregoing is correct. /S/ Bruce S. Luckman BRUCE S. LUCKMAN Case 2:10-cv-00986-NBF -LPL Document 27 Filed 11/18/10 Page 5 of 5