LAW OFFICES GOODWIN & GOODWIN, LLP 300 SUMMERSTREET, SUITE 1500 CHARLESTON, WEST VIRGINIA 25301-1678 P 0 Box 2107 201 THIRD STREET CHARLESTON, WEST VIRGINIA 25328-2107 PARKERSBURC. WEST VIRGINIA 26101 (304) 485-2345 TELEPHONE (304) 346-7000 TELECOPIER (304) 344-9692 www.goodwingoodwin.com PO. Box 349 500 CHURCH STREET RIPLEY, WEST VIRGINIA 25271 (304) 372-2651 Sandra S. Squire Executive Secretary Public Service Commission 201 Brooks Street Charleston, West Virginia 25323 April 9,2008 Via Hand Delive u ) Q a Qr Re: Case No. 08-0298-T-PC Intrado Communications Inc. and Verizon West Virginia Inc. Petition for Compulsory arbitration of the interconnection agreement between Intrado Communications, Inc. and Verizon West Virginia Inc. Dear Ms. Squire: Enclosed please find an original and twelve (12) copies of the following documents in connection with the above referenced civil action: 1. A Motion for Pro Hac Vice Admission of Darrell Townsley; 2. The Verified Statement of Application of Darrell Townsley for Pro Hac Vice Admission; 3. A copy of the correspondence to Kathy Henning of the West Virginia State Bar dated this date. If you have any questions, please let me know. Sincerely, JJS/ph Enclosures WV State Bar ID #3576 cc: Kathy Henning, Executive Secretary, WV State Bar Association
CASE NO. 08-0298-T-PC PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CHARLESTON INTRADO COMMUNICATIONS INC., and VERIZON WEST VIRGINIA INC. Petition for compulsory arbitration of the interconnection agreement between Intrado Communications, Inc., and Verizon West Virginia Inc. MOTION FOR PRO HAC VICE ADMISSION OF DARRELL TOWNSLEY Pursuant to Rule 8.0 of the Rules of Admission to the Practice of Law in the State of West Virginia, Darrell Townsley, an applicant for pro hac vice admission in this proceeding, and Joseph J. Starsick, Jr., of the law firm of Goodwin & Goodwin, LLP, as a member in good standing of The West Virginia State Bar, who agrees to and will be the responsible local attorney in this matter under Rule 8.0 of the Rules of Admission to the Practice of Law in the State of West Virginia, hereby move the Commission to grant Darrell Townsley, an attorney who is not licensed and admitted to the practice of law in West Virginia, the privilege to appear before this Commission, for the purpose of representing Verizon West Virginia Inc. ( Verizon WV ) in this proceeding. The Verified Statement of Application of Darrell Townsley for Pro Hac Vice Admission is attached hereto and submitted herewith in support of this Motion. WHEREFORE, the undersigned respectfully move that this Commission or its designated Administrative Law Judge approve the admission pro hac vice of Darrell Townsley, representing Verizon West Virginia Inc. ( Verizon WV ).
Respectfully submitted, Darrell Townsley Assistant General Counsel Verizon Corporate Services Corporation 205 North Michigan Avenue, Suite 1 100 Chicago, IL 60601 (312) 260-3533 Goodwin & Goodwin, LLP 300 Summers Street, Suite 1500 Charleston, West Virginia 25301-1678 (304) 346-7000 2
CASE NO. 08-0298-T-PC PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CHARLESTON INTRADO COMMUNICATIONS INC., and VERIZON WEST VIRGINIA INC. Petition for compulsory arbitration of the interconnection agreement between Intrado Communications, Inc., and Verizon West Virginia Inc. VERIFIED STATEMENT OF APPLICATION OF DARRELL TOWNSLEY FOR PRO HAC VICE ADMISSION Pursuant to Rule 8.0(b) of the Rules of Admission to the Practice of Law in the State of West Virginia, I, Darrell Townsley, hereby submit the following verified statement in support of the Motion for Pro Hac Vice Admission before this Commission in this proceeding: 1. I am a member in good standing of the bar of the state of Illinois. I have never been the subject of any disciplinary hearing and have not been disciplined at any time by any court or bar. 2. The name, addresses and telephone number of the disciplinary agency of attorneys in Illinois is the Attorney Registration and Disciplinary Commission of the Supreme Court of Illinois, One Prudential Plaza, 130 East Randolph Drive, Chicago, Illinois 60601-621 9, (3 12) 565-2600. 3. I am admitted before the Illinois Supreme Court, U.S. Court of Appeals for the District of Columbia Circuit, and U.S. Court of Appeals for the Eleventh Circuit.
4. I am employed in-house as Assistant General Counsel by Verizon Corporate Services Corporation. 5. I wish to appear and participate in this particular proceeding in association with Joseph J. Starsick, Jr., of the law firm of Goodwin & Goodwin, LLP, who is a member of the bar of the Supreme Court of Appeals of the State of West Virginia and who is authorized to practice law before this Commission. 6. I expressly designate Joseph J. Starsick, Jr., of the law firm of Goodwin & Goodwin, LLP, who has an actual physical office for the practice of law within the State of West Virginia at 300 Summers Street, Suite 1500, Charleston, West Virginia 25301-1678, (304) 346-7000, to serve as the responsible local attorney in this proceeding. 7. I have knowledge of the Rules of this Commission and will comply with all laws, rules and regulations of West Virginia state and local governments, where applicable, including taxing authorities and any standards for pro bono civil and criminal defense legal services. 8. I have not appeared within the last two years before the Courts of the State of West Virginia. I have appeared pro hac vice before this Commission in the following matter within the last two years: Case No. 07-0544-T-PC, Petition for Compulsovy Arbitration of the Interconnection Agreement between EasterbrookeCellular Corporation and Verizon West Virginia Inc. 2
9. Pursuant to Rule 8(b) of the Rules of Admission to the Practice of Law in the State of West Virginia, a copy of this Verified Statement of Application of Darrell Townsley and payment of the required +UO hundred 2 T? >. fifty dollars ($/R 50) is being provided to The West Virginia State Bar. Respectfully submitted, APPLICANT:,/ / sistant General Counsel Verizon Corporate Services Corporation 205 North Michigan Avenue, Suite 1100 Chicago, IL 60601 (312) 260-3533 ENDORSED BY: Goodwin & Goodwin, LLP 300 Summers Street, Suite 1500 Charleston, West Virginia 25301-1678 (304) 346-7000 3
VERIFICATION Darrell Townsley, being first duly sworn, says, upon his oath, that the statements in the forgoing VERIFIED STATEMENT OF APPLICATION OF DARRELL TOWNSLEY FOR PRO HAC ADMISSION are true and correct. Taken, subscribed and sworn before me this - / day of April, 2008. Lm Notary Public My commission expires: yla6;57 c7, dg E?? I MY OFFICIAL SEAL CAMILLE BATES NOTARY PUBLIC - STATE OF ILLINOIS CofulMIssION EXPIRES:08109M9 I 4
LAW OFFICES GOODWIN & GOODWIN, LLP 300 SUMMERS STREET, SUITE 1500 CHARLESTON, WEST VIRGIN I A 25301 -I 678 P 0 Box 2107 201 THIRD STREET CHARLESTON, WEST VIRGINIA 25328-2107 PARKERSBURC. WEST VIRGINIA 26101 (304) 485-2345 TELEPHONE (304) 346-7000 TELECOPIER (304) 344-9692 www.goodwingoodwin.com PO BOX 349 500 CHURCH STREET RIPLEY, WE5T VIRGINIA 25271 (304) 372-2651 April 9, 2008 Kathy Henning Executive Secretary The West Virginia State Bar 2006 Kanawha Boulevard, East Charleston, West Virginia 253 11-2204 Re: PSC Case No. 08-0298-T-PC Dear Ms. Henning: Intrado Communications Inc. And Verizon West Virginia Inc. Petition for compulsory arbitration of the interconnection agreement between Intrado Communications Inc. and Verizon West Virginia Inc. Pursuant to Rule 8.0 of the West Virginia Rules for Admission to the Practice of Law, enclosed please find the following in connection with the referenced matter before the West Virginia Public Service Commission: 1. A Verified Statement of the Application for Pro Hac Vice Admission of Darrell Townsley for Pro Hac Vice Admission; 2. 3. 4. 5. A Verified Statement of the Application for Pro Hac Vice Admission of Joseph M. Ruggiero for Pro Hac Vice Admission; A Motion for Pro Hac Vice Admission of Darrell Townsley; A Motion for Pro Hac Vice Admission of Joseph M. Ruggiero; and A check issued in the amount of $500.00 for the requisite admission fees. v Your assistance in this matter is appreciated. If there are any questions, please let me know.
GOODWIN & GOODWIN, LLP Sincerely, - &75J&ZZ Joseph J. Starsick, Jr. JJS/ph Enclosures cc: West Virginia Public Service Commission
CERTIFICATE OF SERVICE I, Joseph J. Starsick, Jr., Counsel for Verizon West Virginia Inc. do hereby certify that I have served the foregoing Motion for Pro Hac Vice Admission of Darrell Townsley, Verified Statement of Application of Darrell Townsley for Pro Hac Vice Admission, and a copy of the correspondence to Kathy Henning of the West Virginia State Bar upon the parties of record by depositing a true copy thereof in an envelope in the United States mail, this 9th day of April, 2008, addressed as follows: E. Dandridge McDonald, Esq. Steptoe & Johnson PLLC Chase Tower - 8th Floor P. 0. Box 1588 Charleston, WV 25326-1588 Cherie R. Kiser, Esq. Angela F. Collins, Esq. Cahill Gordon & Reindel LLP 1990 K. Street, N.W. - Suite 950 Washington, D.C. 20006 Josephs starsh, Jr. (WV Stat6 Bar ID #3576)