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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF COLORADO In re: CORDILLERA GOLF CLUB, LLC d/b/a THE CLUB AT CORDILLERA, Debtor. ) ) ) ) ) )
MOTION FOR PRO HAC VICE ADMISSION OF CHRISTOPHER CELENTINO FOR DEBTOR CORDILLERA GOLF CLUB, LLC d/b/a THE CLUB AT CORDILLERA
Pursuant to L.B.R. 9010-1(b), the undersigned hereby moves for the admission, pro hac vice, of Christopher Celentino, to participate in the conduct of this case and related proceedings as counsel for Cordillera Golf Club, LLC d/b/a The Club at Cordillera (the Debtor). In support of this motion, the undersigned states as follows: 1. On June 26, 2012, the Debtor filed its voluntary petition for relief under Chapter
11 of title 11, U.S.C. (the Bankruptcy Code) in the United States Bankruptcy Court for the District of Delaware, commencing bankruptcy case number 12-11893 (CSS) (the Delaware Case). 2. On July 16, 2012, venue was transferred to the United States Bankruptcy Court
for the District of Colorado, commencing bankruptcy case number 12-24882 ABC (this Bankruptcy Case). 3. Mr. Celentino is an attorney with the law firm Foley & Lardner LLP and practices
in the firms San Diego, California office located at 402 West Broadway, Suite 2100, San Diego, CA 92101. The firm represents the Debtor in matters related to the Delaware Case.
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is admitted to practice in the United States District Court for the Southern, Northern, Central and Eastern Districts of California, and the Ninth Circuit Court of Appeals. The bar number corresponding to Mr. Celentinos admission is listed in the verified statement of Mr. Celentino in support of this Motion, attached as Exhibit A. As affirmed by Mr. Celentino in Exhibit A, he is in good standing as a member of the Bar of the State of California. 5. Mr. Celentino has associated with the undersigned in connection with this matter.
The undersigned is authorized to practice in this Court and shall participate meaningfully in the case as local Colorado counsel. WHEREFORE, the undersigned requests entry of an order granting this motion admitting Christopher Celentino, pro hac vice, for representation of Cordillera Golf Club, LLC d/b/a The Club at Cordillera in this matter and for other relief as deemed appropriate. Dated: July 20, 2012 SENDER & WASSERMAN, P.C. /s/ Harvey Sender Harvey Sender, #7546 1660 Lincoln Street, Suite 2200 Denver, CO 80264 Telephone: 303-296-1999 Facsimile: 303-296-7600 Email: sender@sendwass.com Proposed Counsel for Debtor and Debtor in Possession
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CERTIFICATE OF SERVICE I hereby certify that on the 20th day of July, 2012, a true and correct copy of the foregoing MOTION FOR PRO HAC VICE ADMISSION OF CHRISTOPHER CELENTINO FOR DEBTOR CORDILLERA GOLF CLUB, LLC d/b/a THE CLUB AT CORDILLERA was deposited in the U.S. Mail, first class postage prepaid, to the addresses listed on the attached.
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Case:12-24882-ABC Doc#:204 J. Abramowitz Label Matrix for local noticing Arthur Filed:07/20/12 1082-1 Liberty View Case 12-24882-ABC Suite 300 District of Colorado 457 Haddonfield Road Denver Cherry Hill, NJ 08002-2220 Fri Jul 20 10:17:42 MDT 2012 Garry R. Appel Joseph M Barry 1660 17th St. 1000 N. King Street Ste. 200 Wilmington, DE 19801 Denver, CO 80202-1281
William P. Bowden 500 Delaware Ave. 8th Fl. PO Box 1150 Wilmington, DE 19899-1150 Mikel R. Bristrow 402 W. Broadway Ste. 2100 San Diego, CA 92101-8510
Kathryn M.S. Catherwood 402 W. Broadway Ste. 2100 San Diego, CA 92101-8510
Benjamin W. Keenan 500 Delaware Ave. 8th Fl. PO Box 1150 Wilmington, DE 19899-1150 Vincent J. Marriott 1735 Market Street 51st Floor Philadelphia, PA 19103-7507
Michael S. Kogan 1901 Avenue of the Stars Suite 1050 Los Angeles, CA 90067-6036
Case:12-24882-ABC Doc#:204 Filed:07/20/12 Russell L. Munsch Brittany J. Nelson 500 N. Akard Street 3000 K St., N.W. Suite 3800 Ste. 600 Dallas, TX 75201-6659 Washington, DC 20007-5109
Ricardo Palacio 500 Delaware Avenue 8th Floor P.O. Box 1150 Wilmington, DE 19899-1150 Matthew J. Riopelle 402 W. Broadway Ste. 2100 San Diego, CA 92101-8510
Jon Pearson 100 North City Parkway Suite 1750 Las Vegas, NV 89106-4617
Damien Tancredi 1201 North Market Street Suite 1400 Wilmington, DE 19801-1163
Ann Marie Uetz One Detroit Center 500 Woodward Ave. Ste. 2700 Detroit, MI 48226-3489 Gregory W. Werkheiser 1201 N. Market St. 18th Fl. PO Box1347 Wilmington, DE 19899-1347 Risa Lynn Wolf-Smith 555 17th St. Ste. 3200 Denver, CO 80202-3921
The following recipients may be/have been bypassed for notice due to an undeliverable (u) or duplicate (d) address.
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EXHIBIT A
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VE RI FIED STATEMENT IN SUPPORT OF MOT ION FOR PRO HAC VICE AD MISSION
1, Christopher Celentino, depose and say under the pena lty of perjury: l. I am an attorney with the law flrm Foley & Lardner LLP and practice in the
firm 's San Diego, California office located at 402 West Broadway, Suite 2 100, San
Diego, CA 9210 l . T he firm represents the above-captioned debtor in matters related to the above-captioned bankruptcy case. 2. I am licensed to practice law in the State of California (bar no. 131688) and
admitted to practice in the United States DistJict Court for the Southern, Northern, Central and Eastern Districts of Califorrtia, and the Ninth Circui t court of Appeals. I am
in good standing as a member of the Bar of the State of Cali forma.
Ill
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connection w ith this matter. Mr. Sender i authorized to practice in this Court and shall participate meaningfully in the case as local Colorado counsel. Further 1 sayeth not. Dated this 19th day of July, 2012.
Chri stopher Celentino FOLEY & LARDNER LLP 402 West Broadway Suite 2100 San Diego, CA 92101-3542
) ) ss: )
Subscribed and sworn to (or affu-med) before me on this 19th day of July, 2012, by Christopher Celentino, proved to me on the basis of satisfactory evidence to be the person(s) who appeared before me. WITNESS my hand and official seal.
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[SEAL]
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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF COLORADO In re: CORDILLERA GOLF CLUB, LLC d/b/a THE CLUB AT CORDILLERA, Debtor. ) ) ) ) ) )
ORDER GRANTING MOTION FOR PRO HAC VICE ADMISSION OF CHRISTOPHER CELENTINO
THIS MATTER is before the Court on the Motion for Pro Hac Vice Admission of Christopher Celentino for Debtor Cordillera Golf Club, LLC d/b/a The Club at Cordillera (the Motion). The Court has reviewed the Motion and the file and is otherwise advised. Pursuant to L.B.R. 9010-1(b), the Motion is hereby GRANTED and Christopher Celentino is hereby admitted, pro hac vice, to participate in this case and related proceedings. Dated this ___ day of July, 2012. BY THE COURT:
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