IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`JENNIFER CHAMBERLAIN,
`
`CIVIL ACTION - ASBESTOS
`
`Plaintiff,
`
`GD No. 22-005532
`
`V.
`
`AVON PRODUCTS, LNTC, et al,
`
`Defendants.
`
`MOTION FOR PRO HAC VICE
`ADMISSION OF JORDAN L. BOLLINGER
`
`Filed on Behalf of Plaintiff
`
`Counsel of Record for this Party:
`
`Cori J. Kapusta, Esquire
`PA LD. #91958
`
`Anthony J. Bianco, Esquire
`PA LD. #324485
`
`THE LAW OFFICES OF KAPUSTA &
`SCHWEERS
`
`445 Fort Pitt Boulevard, Suite 500
`Pittsburgh, PA 15219
`(412)904-5080
`
`
`
`JENNIFER CHAMBERLAIN,
`
`CIVIL ACTION - ASBESTOS
`
`Plaintiff,
`
`GD No. 22-005532
`
`V.
`
`AVON PRODUCTS, LNTC, et al,
`
`Defendants.
`
`MOTION FOR PRO HAC VICE
`ADMISSION OF JORDAN L. BOLLINGER
`
`Filed on Behalf of Plaintiff
`
`Counsel of Record for this Party:
`
`Cori J. Kapusta, Esquire
`PA LD. #91958
`
`Anthony J. Bianco, Esquire
`PA LD. #324485
`
`THE LAW OFFICES OF KAPUSTA &
`SCHWEERS
`
`445 Fort Pitt Boulevard, Suite 500
`Pittsburgh, PA 15219
`(412)904-5080
`
`
`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`JENNIFER CHAMBERLAIN,
`
`CIVIL ACTION - ASBESTOS
`
`Plaintiff,
`
`GD No. 22-005532
`
`V.
`
`AVON PRODUCTS, INC., et al.,
`
`Defendants.
`
`MOTION FOR PRO HAC VICE
`ADMISSION OF JORDAN L. BOLLINGER
`
`Pursuant to Pennsylvania Bar Admission Rule 301 and Pennsylvania Rule of Civil
`
`Procedure 1012.1, Con J. Kapusta and Jordan L. Bollinger, counsel for Plaintiff, avers as follows:
`
`1. Jordan L. Bollinger is an attorney with Dean Omar Branham Shirley, LLP, 302 N.
`
`Market Street, Suite 300, Dallas, TX 75202.
`
`2. Jordan L. Bollinger has been a member in good standing of the state bar of
`
`Louisiana (No. 35663) since 2014. Since 2015, Ms. Bollmger has also been admitted to practice
`
`in the United States District Courts for the Eastern, Western, and Middle Districts of Louisiana.
`
`She was previously admitted in 2015, to the United States 5 Circuit Court of Appeals, but allowed
`
`her membership to lapse.
`
`3. Jordan L. Bollinger has never been suspended, disbarred, or disciplined in any of
`
`the jurisdictions listed above, and is not subject to any pending disciplinary proceedings.
`
`4. Jordan L. Bollinger will comply with the Pennsylvania Rules of Civil Procedure,
`
`the Pennsylvania Rules of Professional Conduct, and the applicable Local Rules.
`
`5. The verified statement required by Pa.R.C.P. 1012.l(c) is attached to this Motion
`
`and incorporated herein as Exhibit A.
`
`
`
`6. The verified statement required by Pa.R.C.P. 1012.1(d)(2) is attached to this
`
`Motion and incorporated herein as Exhibit "B."
`
`7. The undersigned counsel has entered her appearance as attorney of record in this
`
`action on behalf of Plaintiff.
`
`8. The information required by Section 81.504 of the Pennsylvania Interest on Lawyer
`
`Trust Account Board Regulation for Pro Hac Vice Admission ("IOLTA") has been provided.
`
`9. The fee required by Section 81.505(a) of the IOLTA Regulations has been paid.
`
`See attached Exhibit "C."
`
`10. No good cause for denial exists.
`
`WHEREFORE, the undersigned counsel for Plaintiff respectfully requests that this
`
`Honorable Court enter and Order in the form attached hereto admitting Jordan L. Bollinger pro
`
`hac vice to practice before this Court for all discovery, motions and trial in this matter.
`
`^
`
`Dated: September ^ , 2022 Respectfully submitted,
`
`By:.
`
`r K^pif&ta^Esq.
`PAte<91958
`THE LAW OFFICES OF
`KAPUSTA & SCHWEERS
`445 Fort Pitt Blvd., Suite 500
`Pittsburgh, PA 15219
`
`Counsel for Plaintiff
`
`
`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,
`PENNSYLVANIA
`
`JENNIFER CHAMBERLAIN )
`)
`Plaintiff, )
`)
`v. ) GD No. 22-005532
`)
`AVON PRODUCTS, INC, et al., )
`)
`Defendants )
`
`))
`
`VERIFIED STATEMENT OF CAMUDATE JORDAN L. BOLUNGER
`
`Pursuant to Rule 1012.1 of the Pennsylvania Rules of Civil Procedure, Jordan L. Bollinger,
`
`a candidate for pro hac vice admission, verifies as follows:
`
`1. I am a member in good standing of the state bar of Louisiana having been admitted in 20 14
`
`(No. 35663). I have also been admitted to the United States District Courts for the Eastern,
`
`Western, and Middle Districts of Louisiana since 2015.1 previously was admitted to the
`
`United States Fifth Circuit Court Appeals in 2015, however I allowed my membership to
`
`lapse,
`
`2. I have never been suspended, disbarred, or disciplined iu any of the jurisdictions listed
`
`above. I am currently not subject to any pending disciplmary proceedings.
`
`3. I applied for admission pro hac vice in Pennsylvama in the followuig;
`
`/'
`Chamberlain w. Avon Produce Inc^ et at GD no. 22-Q05532
`
`4. I will comply with and be bound by the applicable statutes^ case law, and procedures mles
`
`of the Commonwealth of Pennsylvania, including the Pennsylvania Rules of Professional
`
`Conduct.
`
`5. I will submit to the jurisdiction of the Pennsylvania courts and the Pennsylvania
`
`EXHIBIT
`
`
`
`Disciplinary Board with respects to acts and emissions during the appearance in the matter
`
`for which admission pro hac vice is sought.
`
`6. I have consented to the appointment of my Sponsor, Cori J. Kapusta, and the attorneys of
`
`record from Kapusta & Schweers, as the agents upon whom service of process shall be
`
`made for all actions, including disciplinary actions, if any, which may arise out of the
`
`practice of law in the matter of which pro hac vice is sought.
`
`The information contained in this Verified Statement is true and correct to the best of my
`
`knowledge, information, and belief and is made subject to penalties of IS.Pa.C.S. § 4904 relatmg
`
`to unsworn falsification to authorities.
`
`Dated: September 12, 2022
`
`By:
`
`;r. Esquire
`WHAM SMRLY, LLP
`S02 N. Market Street, Suite 300
`Dallas, TX 75202
`214-722-5990
`iboUinserfaldobsle gal. corn
`
`
`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`JENNIFER CHAMBERLAIN,
`
`CIVIL ACTION - ASBESTOS
`
`Plaintiff,
`
`GD No. 22-005532
`
`V.
`
`AVON PRODUCTS, INC., et al,
`
`Defendants.
`
`SPONSOR VERIFICATION
`
`1. After reasonable investigation, I reasonably believe Jordan L. Bollinger to be a reputable
`and competent attorney, and I am in a position to recommend his admission.
`
`2. The above-captioned case is the only matter in which I am acting as the sponsor of a
`candidate for admission pro hac vice.
`
`3. The proceeds from the settlement of a cause of action in which Jordan L. Bollinger is
`granted admission7?ro hac vice shall be received, held, distributed and accounted for in accordance
`with Rule 1.14 of the Pennsylvania Rules of Professional Conduct, including IOLTA provisions
`thereof, if applicable.
`
`Dated: September ] ^ , 2022
`
`cpo^p^—-
`Ista, Esq.
`r91958
`
`
`
`SUPREME COURT OF PENNSYLVANIA
`PENNSYLVANIA INTEREST ON
`LAWYERS TRUST ACCOUNT BOARD
`
`September 02, 2022
`
`JORDAN LYNN BOLUNGER, Esq.
`DEAN OMAR BRANHAM & SHIRLEY, LLP
`302 N MARKET STREET
`STE #300
`DALLAS, TX 75202
`
`SENT TO JORDAN BOLLINGER VIA Email: JBOLLINGER@DOBSLEGAL.COM
`
`Dear Attorney BOLLINGER:
`
`This letter serves as the fee payment certification referenced in 204 Pa Code §81.503 and
`acknowledges receipt of the $375.00 fee paid by Online Payment on this date related to your
`pursuit for admission pro hac vice in the case identified as Jennifer Chamberlain vs. Avon Products,
`no. GD 22-005532. filed in Court of Common Pleas of Allegheny County.
`
`You should refer to Pa Rule of Civil Procedure 1012.1, local court rules, and other regulations of
`204 Pa Code §81.501 et. seq. concerning additional requirements related to seeking pro hac vice
`admission.
`
`Sincerely,
`
`^3^W/^
`
`Stephanie S. Libhart
`Executive Director
`
`ec: CORI JESSICA KAPUSTA. Esq.
`
`kapusta@kdslaw.com
`
`Pennsylvania Judicial Center
`601 Commonwealth Ave., Ste. 2400
`PO Box 62445, Harrisburg, PA 17106-2445
`717/238-2001 • 888/PA-IOLTA (724-6582) • 717/238-2003 FAX
`paiolta@pacourts.us • www.paiolta.org
`
`Administering Pennsylvania's Interest On Lawyers Tmst Account (IOLTA) Program
`
`
`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`JENNIFER CHAMBERLAIN,
`
`CIVIL ACTION - ASBESTOS
`
`Plaintiff,
`
`GD No. 22-005532
`
`V.
`
`AVON PRODUCTS, INC., et aL,
`
`Defendants.
`
`CERTIFICATE OF SERVICE
`
`We hereby certify that a true and correct copy of the foregoing Motion for Pro Hac Vice
`
`Admission of Jordan L. Bollinger, was served on All Counsel of Record for the Plaintiff by
`
`electronic and/or regular mail this _C^_ day of September, 2022 by serving:
`
`THE LAW OFFICES OF KAPUSTA &
`SCHWEERS
`
`Cori/T. 15&]5usfa, Esq.
`PA ?^#91958
`
`Counsel for Plaintiff
`
`
`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`JENNIFER CHAMBERLAIN
`
`CIVIL ACTION - ASBESTOS
`
`Plaintiff,
`
`GD No. 22-005532
`
`V.
`
`AVON PRODUCTS, INC, et al,
`
`Defendants.
`
`ORDER AUTHORIZING PRO HAC VICE
`ADMISSION OF JORDAN L. BOLLINGER
`
`AND NOW, this
`
`day of July, 2022, upon consideration of the verified Motion for
`
`Admission of Coimsel Pro Hac Vice, and any response thereto, it is hereby ORDERED that the
`
`Motion is GRANTED; and it is FURTHER ORDERED that JORDAN L. BOLLINGER is
`
`admitted pro hac vice to practice before this Court for all discovery, motions and trial in this
`
`matter. CORI J. KAPUSTA shall remain counsel of record.
`
`J.
`
`
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