In the United States Bankruptcy Court for the Western District of Kentucky

Case 20-40133-thf Doc 28 Filed 02/21/20 Entered 02/21/20 09:27:16 Page 1 of 10 Docket #28 Date Filed: 02/21/2020

IN THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF KENTUCKY

In re: ) Chapter 11 ) Hartshorne Holdings, LLC, et al., ) Case No. 20-40133 ) 1 Debtors. ) (Joint Administration Requested)

MOTION FOR ADMISSION TO PRACTICE PRO HAC VICE OF MAURA P. MCINTYRE

Hartshorne Holdings, LLC and its affiliated debtors and debtors-in-possession

(collectively, the “Debtors”) in the above-captioned chapter 11 cases hereby move (the

“Motion”) this Court, pursuant to Rule 83.2 of the Joint Local Rules of Civil Practice for the

Eastern and Western Districts of Kentucky (the “Local Rules”), for entry of an order,

substantially in the form as the proposed order tendered contemporaneously with this Motion,

admitting pro hac vice Maura P. McIntyre (the “Applicant”) in the above-referenced case. In

support of the Motion, the Debtors rely upon and incorporate by reference the Declaration of

David Gay in Support of Chapter 11 Filings and First Day Motions (the “First Day

Declaration”),2 which was filed contemporaneously herewith. In further support of the Motion,

the Debtors respectfully state as follows:

1. The Applicant is a member in good standing of the bar of the State of Ohio and

the Commonwealth of Pennsylvania, and is admitted to practice before the United States District

Court for the Western District of Pennsylvania.

2. The Applicant consents to be subject to the jurisdiction and rules of the Kentucky

Supreme Court governing professional conduct.

1 The Debtors in these chapter 11 cases and the last four digits of each Debtors’ taxpayer identification number are as follows: Hartshorne Holdings, LLC (3948); Hartshorne Mining Group, LLC (0063); Hartshorne Mining, LLC (1941) and Hartshorne Land, LLC (5582). The Debtors’ headquarters are located at 373 Whobry Road, Rumsey, Kentucky 42371.

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3. The Applicant’s mailing address, telephone number, and e-mail address are:

Maura P. McIntyre Squire Patton Boggs (US) LLP 4900 Key Tower 127 Public Square Cleveland, OH 44114 Telephone: 216.479.8500 Facsimile: 216.479.8780 [email protected]

4. Attached to this Motion is Exhibit A and incorporated by reference is the

Affidavit of the Applicant (the “Affidavit”) in support of this Motion.

5. The Applicant is an attorney of good moral and professional character and is

eligible for admission to the Bar of this Court. She is registered as an ECF participant in the

United States Court for the Western District of Pennsylvania, and has completed ECF training

through that court.

6. Attached to this motion is Exhibit B and incorporated by reference is the

Applicant’s Certificate of Good Standing issued by the highest court of the State of Ohio, where

the Applicant is a resident.

7. The Applicant is submitting the prescribed fee of $125.00.

2 Capitalized terms used but not otherwise defined herein shall have the meaning ascribed to them in the First Day Declaration. 2

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WHEREFORE, the undersigned respectfully requests entry of the order, substantially in

the form as the proposed order tendered contemporaneously with the Motion, admitting Maura P.

McIntyre pro hac vice to appear before this Court in the above-captioned chapter 11 cases and all

associated adversary proceedings on behalf of the Debtors.

Respectfully submitted,

FROST BROWN TODD LLC

/s/ Edward M. King Edward M. King Bryan J. Sisto 400 West Market Street, Suite 3200 Louisville, Kentucky 40202 Telephone: 502.589.5400 Facsimile: 502.581.1087 [email protected] [email protected]

Proposed Co-Counsel to the Debtors and Debtors-in-Possession

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CERTIFICATE OF SERVICE

This is to certify by the undersigned that the foregoing was served electronically in accordance with the method established under this Court’s CM/ECF Administrative Procedures upon all parties in the electronic filing system in this case on the date set forth in the header to this Certificate of Service.

/s/ Edward M. King Edward M. King

Proposed Co-Counsel to the Debtors and Debtors-in-Possession

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Exhibit A

Affidavit of the Applicant Case 20-40133-thf Doc 28 Filed 02/21/20 Entered 02/21/20 09:27:16 Page 6 of 10

IN THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF KENTUCKY (Owensboro Division)

In re: ) Chapter 11 ) Hartshorne Holdings, LLC, et al., ) Case No. 20-40133 ) 1 Debtors. ) (Joint Administration Requested)

STATE OF OHIO ) ) ss: COUNTY OF CUYAHOGA )

AFFIDAVIT OF MAURA P. MCINTYRE IN SUPPORT OF MOTION FOR ADMISSION OF MAURA P. MCINTYRE, PRO HAC VICE

I, Maura P. McIntyre, having been first duly sworn upon oath, do depose and state the

following:

1. My name is Maura P. McIntyre. I am an attorney serving as counsel for

Hartshorne Holdings, LLC and its affiliated debtors and debtors-in-possession (collectively, the

“Debtors”) in the above-captioned chapter 11 cases

2. I have personal knowledge of the facts stated herein.

3. I am a member in good standing of the bar of the State of Ohio and the State of

Pennsylvania, and am admitted to practice before the United States District Court for the

Western District of Pennsylvania.

4. I am a member in good standing to practice before each of the courts listed in the

preceding paragraph of this Affidavit, and I have been in good standing since the date that I was

admitted to practice before each such court.

5. I have obtained a copy of and familiarized myself with the Joint Local Rules of

Civil Practice for the United States District Court for the Western District of Kentucky. Pursuant

to the written consent attached hereto, I agree to be subject to the jurisdiction and rules of the

Kentucky Supreme Court governing professional conduct.

6. I am not currently the subject of any professional disciplinary sanction,

proceeding, or investigation in any jurisdiction.

7. I am not currently nor have never been disbarred, suspended from practice, or

subject to other disciplinary action by any court, state, territory or the District of Columbia.

8. I have not previously filed for permission to appear pro hac vice before this Court

in the above-captioned chapter 11 cases.

9. I hereby certify that I am familiar with and will at all times comply with the

United States Bankruptcy Code, the Federal Rules of Bankruptcy Procedure, the Federal Rules

of Civil Procedure, the Federal Rules of Evidence and the Local Rules of this Court.

10. I hereby certify that I have CM/ECF training on the use of the electronic filing

system provided in the United States Court for the Western District of Pennsylvania, and have

completed ECF training through this court.

FURTHER AFFIANT SAYETH NAUGHT.

3 Case 20-40133-thf Doc 28 Filed 02/21/20 Entered 02/21/20 09:27:16 Page 8 of 10

Maura ntyre

Sworn to before me and signed before me, a Notary Public in and for said county and state by Maura P. McIntyre, this ~Lday of February, 2020.

~ ~ ~ `, Notary P

•~AaY ~~e. ~0=~~1[//i~t~~?~c.. KEI.LYR CONROY, Mot~y publ~ =*` '*= State of Ohio _~;;. ~o My Canm~sion E~ires Octob~lb 20~,~ o.~ Case 20-40133-thf Doc 28 Filed 02/21/20 Entered 02/21/20 09:27:16 Page 9 of 10

EXHIBIT B

Applicant’s Certificate of Good Standing Case 20-40133-thf Doc 28 Filed 02/21/20 Entered 02/21/20 09:27:16 Page 10 of 10

-"~'-:.~ , THE SUPREME COURT of OHIO CERTIFICATE OF GOOD STANDING

I, GINA WHITE PALMER, Director of the Attorney Services Division of the Supreme Court of Ohio, do hereby certify that I am the custodian of the records of the Office of Attorney Services of the Supreme Court and that the Attorney Sereices Division is responsible for reviewing Court records to determine the status of Ohio attorneys. I further certify that, having fulfilled all of the requirements for admission to the practice of law in Ohio,

Maura Patricia McIntyre Attorney Re,istration No. 0098484

was admitted to the practice of law in Ohio on May 13, 2019; has registered as an active attorney pursuant to the Supreme Court Rules for the Government of the Bar of Ohio; is in good standing with the Supreme Court of Ohio; and is entitled to practice law in this state.

---- ~..~„~; IN TESTIMONYWHEREOF, I have ,; '~,!~,~~ }_~~ >~: ~~, subscribed my name and affixed the seal of '-' ~ '~ `~'~~ the Supreme Court, this 4th day of ~' ~; . ~ ~~ i~. February, 2020. ~:, ~ ,.~

' . . _ . .__ .-~- '1--,:~ >-=-" GINA WHITE PALMER ~ ~~.~`~ ~ - - ~ Director, Attorney Services Division

f ~~. ~. ~ ~ ~, .. ., .t ~ 7 r ,1f

Shannon Scheid Administrative Assistant, Office of Attorney Services

IIIIII IIII) VIII VIII VIII VIII VIII IIII IIII No. 2020-02-041 Verify by email at Go,SsS:ltit ~~itlir~r;kc;c.}t c~~;ts~z s_c... ol.iic~.:.~ <~ti: Case 20-40133-thf Doc 28-1 Filed 02/21/20 Entered 02/21/20 09:27:16 Page 1 of 2

IN THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF KENTUCKY (Owensboro Division)

In re: ) Chapter 11 ) Hartshorne Holdings, LLC, et al., ) Case No. 20-40133 ) 1 Debtors. ) (Joint Administration Requested)

ORDER ADMITTING MAURA P. MCINTYRE TO PRACTICE PRO HAC VICE

This matter is before the court on the Motion for Admission to Practice Pro Hac Vice of

Maura P. McIntyre (the “Motion”)2 in the above-captioned chapter 11 cases. The Court having

reviewed the Motion, the Affidavit, any opposition to the Motion and being duly and sufficiently

advised, it appears that approval of the Motion is warranted; therefore,

IT IS HEREBY ORDERED:

(1) The Motion is GRANTED;

(2) The admission fees having been paid, Maura P. McIntyre shall be admitted to

appear pro hac vice as counsel for the Debtors; and

(3) Maura P. McIntyre shall be subject to the jurisdiction and rules of the Kentucky

Supreme Court governing professional conduct.

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Tendered by:

FROST BROWN TODD LLC

/s/ Edward M. King Edward M. King Bryan J. Sisto 400 West Market Street, Suite 3200 Louisville, Kentucky 40202 Telephone: 502.589.5400 Facsimile: 502.581.1087 [email protected] [email protected]

Proposed Co-Counsel to the Debtors and Debtors-in-Possession

2 Capitalized terms used not otherwise defined herein shall have the meaning ascribed to them in the Motion.

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