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Law Offices of: PHILIP J. BERG, ESQUIRE Identification No. 09867 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Ph: (610) 825-3134 Fx: (610) 834-7659 Email: philjberg@gmail.com

Applicant Seeking Pro Hac Vice Admission

U.S. DISTRICT COURT, NORTHERN DISTRICT OF TEXAS AMARILLO DIVISION _____________________________________________ : LISA LIBERI, et al, Plaintiffs, : CIVIL ACTION : vs. : : Case No. 2:11-cv-00090-J : LINDA SUE BELCHER, et al, : Honorable Mary Lou Robinson : Defendants. : APPLICANT, PHILIP J. BERG, ESQUIRE APPLICATION FOR ADMISSION PRO HAC VICE and WAIVER OF THE LOCAL COUNSEL REQUIREMENT PURSUANT TO THIS COURTS LOCAL RULE 83.10 TO THE HONORABLE COURT: 1. Applicant, Philip J. Berg, Esquire is an attorney who practices law in

The Law Offices of Philip J. Berg with offices at 555 Andorra Glen Court, Suite 12, Lafayette Hill, PA, 19444-2531, phone number (610) 825-3134, fax number (610) 834-7659 and email philjberg@gmail.com. 2. 3. Applicant will sign all filings with the name Philip J. Berg. Applicant has been retained personally by Plaintiffs, Evelyn Adams,

Lisa Liberi, Lisa Ostella and Go Excel Global to provide legal representation in connection with the above-styled matter now pending before the United States
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Philip J. Berg, Esquire Application for pro hac vice Admission

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District Court for the Northern District of Texas, Amarillo Division. In addition, Applicant has been Counsel for the Plaintiffs since the filing of this case on May 4, 2009 in the Commonwealth of Pennsylvania. Counsel is very familiar with the case at hand and is willing and ready to continue his representation of the Plaintiffs in the Northern District of Texas, Amarillo Division. 4. Applicant is a member in good standing of the bar of the highest

Court in the Commonwealth of Pennsylvania, where Applicant regularly practices law. Applicants bar number is 09867 and was admitted to practice law in the

Commonwealth of Pennsylvania, November 18, 1971. Applicant has attached hereto as EXHIBIT A his letter of good standing from the Commonwealth of Pennsylvania Supreme Court. 5. Courts: a. U.S. District Court, Eastern District of PA b. U.S. Court of Appeals for the Third Circuit c. U.S. Supreme Court 6. December 12, 1972 1983 August 2, 1996 Applicant has also been admitted to practice before the following

Applicant has never involuntarily lost, temporarily or permanently,

the right to practice before any Court or tribunal, or resigned in lieu of discipline. 7. Applicant has never been subject to grievance proceedings or

involuntary removal proceedings regardless of outcome while a member of the

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bar of any state or Federal Court except for a complaint filed against him in the Commonwealth of Pennsylvania by an unhappy client as a result of her 2006 Case. 8. Applicant has not been charged, arrested or convicted of a criminal

offense or offenses. 9. Applicant has not filed for pro hac vice admission in the United States

District Court, Northern District of Texas during the past three (3) years. 10. Applicant has not found local counsel, which satisfies this Courts

Local Rules of being within fifty [50] miles of the Amarillo Courthouse, to sponsor him, and therefore, Applicant is requesting a Waiver of the Requirement for Local Counsel pursuant to this Courts Local Rule 83.10(a). Applicant has been

litigating the within case since it was filed on May 4, 2009 in the U.S. District Court, Eastern District of Pennsylvania and is very familiar with the events to date. Due to the size of the case, it would take new counsel quite some time to familiarize themselves with the purpose of the suit and events which have occurred to date, which would delay the proceedings. 11. Moreover, Applicant is Plaintiffs choice of counsel. Currently, in the

California portion of this Case, Applicant is temporarily admitted pro hac vice to continue representing the Plaintiffs. 12. Applicant has read Dondi Properties Corp. v. Commerce Savs. &

Loan Assn, 121 F.R.D. 284 (N.D. Tex. 1988) (en banc), and the Local Civil Rules
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of this Court and will comply with the standards of practice adopted in Dondi and with the Local Civil Rules. 13. Applicant respectfully requests to be admitted to practice in the

United States District Court for the Northern District of Texas for this cause only. Applicant certifies that a true and correct copy of this document has been served upon each attorney of record or pro se party and the original upon the Clerk of Court, accompanied by a $25.00 filing fee on this 9th day of June, 2011. Respectfully submitted,

Dated: June 10, 2011

/s/ Philip J. Berg PHILIP J. BERG, ESQUIRE, Applicant 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 PA Identification No. 09867 (610) 825-3134

Philip J. Berg, Esquire Application for pro hac vice Admission

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EXHIBIT A
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Case 2:11-cv-00090-J Document 180-1

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Case 2:11-cv-00090-J Document 180-2

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Law Offices of: PHILIP J. BERG, ESQUIRE Identification No. 09867 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Ph: (610) 825-3134

Applicant for pro hac vice Admission

U.S. DISTRICT COURT, NORTHERN DISTRICT OF TEXAS AMARILLO DIVISION _____________________________________________ : LISA LIBERI, et al, Plaintiffs, : CIVIL ACTION : vs. : : Case No. 2:11-cv-00090-J : LINDA SUE BELCHER, et al, : Honorable Mary Lou Robinson : Defendants. : CERTIFICATE OF SERVICE I, Philip J. Berg, Esquire, hereby certify that a copy of my Application for pro hac vice Admission was served this 10th day of June, 2011, upon the following Defendants by U.S.P.S. mail with postage fully prepaid. Edgar Hale Caren Hale Plains Radio Network, Inc. KPRN Bar H Farms 1404 Bowie Street Wellington, Texas 79095 Linda Sue Belcher 201 Paris Street Castroville, TX 78009 /s/ Philip J. Berg PHILIP J. BERG, ESQUIRE
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Philip J. Berg, Esquire Application for pro hac vice Admission Certificate of Service