Gregoire et al v. Transocean, Ltd.

Filing 13

EXPARTE/CONSENT MOTION to Appear Pro Hac Vice (Hariklia Karis) (FEE PAID 6/1/2010) by BP Exploration & Production, Inc., BP Products North America, Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit A, # 3 Proposed Order)(Haycraft, Don) Modified on 6/2/2010 to edit fee status (rll, ).

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA WILLIAM D. GREGOIRE; VERONICA G. STELLY; TOBY J. STELLY versus * * CIVIL ACTION NO. 10-CV-01351

* SECTION "N" TRANSOCEAN, LTD.; TRANSOCEAN OFFSHORE DEEPWATER DRILLING, INC.; * DIVISION "5" TRANSOCEAN DEEPWATER INC.; BP, PLC; BP PRODUCTS NORTH AMERICA, * JUDGE KURT D. ENGELHARDT INC.; BP EXPLORATION & PRODUCTION, INC.; HALLIBURTON ENERGY SERVICES, INC.; HALLIBURTON COMPANY; * MAGISTRATE CAMERON INTERNATIONAL ALMA CHASEZ CORPORATION; ABC INSURANCE * COMPANY; DEF INSURANCE COMPANY; GHI INSURANCE COMPANY; JKL * INSURANCE COMPANY; MNO INSURANCE COMPANY; PQR INSURANCE COMPANY; STU INSURANCE COMPANY; * XYZ INSURANCE COMPANY *************************************** EX PARTE MOTION TO ENROLL COUNSEL PRO HAC VICE NOW INTO COURT comes Don K. Haycraft, counsel for defendants BP Exploration & Production Inc. and BP Products North America, Inc. (collectively the "BP Defendants"), and moves this Court to admit Hariklia Karis, P.C., as counsel pro hac vice to this Court pursuant to Rule 83.2.6 of the Local Rules of the United States District Court for the Eastern District of Louisiana. In support of this motion, Don K. Haycraft avers as follows:

1. Hariklia Karis, P.C., is a member of the bar of the State of Illinois and will represent the BP Defendants along with Liskow & Lewis, its counsel of record in the referenced case. 2. The Affidavit of Hariklia Karis, P.C., attached hereto as Exhibit 1, shows that Ms. Karis has been admitted to practice and is in good standing before all courts of the State of Illinois. In addition, a Certificate of Good Standing issued by the Clerk for the Supreme Court for the State of Illinois is attached to her Affidavit. 3. No disciplinary proceedings or criminal charges have been instituted against Hariklia Karis, P.C., as evidenced by her Affidavit. 4. The mailing address of Ms. Karis is Kirkland & Ellis LLP, 300 North LaSalle Street, Chicago, Illinois, 60654. Her telephone number is [phone], and her facsimile number is [phone]. Her email address is [e-mail].

WHEREFORE, Don K. Haycraft moves this court to enroll Hariklia Karis, P.C., as cocounsel of record pro hac vice for defendants BP Exploration & Production Inc. and BP Products North America, Inc.

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Respectfully submitted, Don K. Haycraft Donald R. Abaunza (Bar #2273) R. Keith Jarrett (Bar #16984) Don K. Haycraft (Bar #14361) Jonathan A. Hunter (Bar #18619) Mark D. Latham (Bar #19673) Robert E. Holden (Bar #6935) LISKOW & LEWIS One Shell Square 701 Poydras Street, Suite 5000 New Orleans, Louisiana 70139-5099 Telephone: [phone] Facsimile: [phone]
/s/

and Of Counsel: Richard C. Godfrey, P.C. John T. Hickey Jr., P.C. J. Andrew Langan, P.C. Matthew T. Regan, P.C. Kirkland & Ellis LLP 300 North LaSalle Street Chicago, IL 60654 [phone] (Tel) [phone] (Fax) Attorneys for BP Exploration & Production Inc. and BP Products North America, Inc.

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CERTIFICATE OF SERVICE I HEREBY CERTIFY that on May 28, 2010, a copy of the foregoing pleading was filed electronically with the Clerk of Court using the CM/ECF system. Notice of this filing will be sent to all counsel of record registered to receive electronic service by operation of the court's electronic filing system. I also certify that I have mailed this filing by United States Postal Service to all counsel of record who are not registered to receive electronic service by operation of the court's electronic filing system. /s/ Don K. Haycraft Don K. Haycraft

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