12-50073-lmc Doc#97 Filed 02/15/12 Entered 02/15/12 14:24:51 Main Document Pg 1 of 3

UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION In re: Delta Produce, L.P.1, Debtor. Case No. 12-50073-LMC Chapter 11 Jointly Administered

MOTION TO APPEAR PRO HAC VICE TO THE HONORABLE JUDGE OF SAID COURT: Comes now Steven E. Nurenberg and moves this court to grant admission to the United States Bankruptcy Court for the Western District of Texas pro hac vice to represent Rio Queen Citrus, Inc., Eco-Farms Sales, Inc., Henry Avocado Corp., Gargiulo, Inc., C & R Fresh, LLC, Duckwall Fruit Co., Fresh Start Produce Sales and Sunriver Sales in these jointly administered cases, and other creditors who may retain the movant during the pendency of these jointly administered cases, and would respectfully show the Court as follows: 1. Applicant is an attorney and member of the law firm of Meuers Law Firm,

P.L., with offices at 5395 Park Central Court, Naples, Florida, 34109, Telephone: (239) 513-9191, Facsimile: (239) 513-9677, and email: snurenberg@meuerslawfirm.com. 2. Since 2004, Applicant has been and presently is a member of and in good

standing with the Bar of the State of Florida. Applicants bar license number is 0808431.

Debtors are the following entities: Delta Produce, L.P. Case No. 12-50073-LMC-11, Superior TomatoAvocado, Ltd. Case No. 12-50074-LMC-11, Atled, Ltd. Case No. 12-50075-LMC-11 and Staci Properties, Ltd. Case No. 12-50110-LMC.
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3.

Applicant has been admitted to practice before the following state and

federal courts: a. State of Michigan b. State of Florida c. State of New York November 21, 1989 September 17, 2004 December 6, 2007 April 28, 2003 May 5, 2003 September 1, 2006 July 20, 2007 December 9, 2008 December 9, 2008 December 3, 2009 October 4, 2004

d. Eastern District of Michigan e. f. Western District of Michigan Middle District of Florida

g. Southern District of Florida h. Southern District of New York i. Eastern District of New York j. Eastern District of Wisconsin

k. U.S. Supreme Court 4.

Applicant is presently a member in good standing of the bars of the courts

listed above, and is not currently suspended or disbarred in any other court. 5. Applicant has never been subject to grievance proceedings or involuntary

removal proceedings while a member of the bar of any state or federal court. 6. 7. Applicant is eligible to practice in the Bankruptcy Court. Applicant has read and is familiar with the Local Rules of the Western

District of Texas Bankruptcy Court and is also subject to all rules of practice of the U.S. District Court of the Western District of Texas and will comply with the standards of practice set out therein.

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8.

Applicant has not requested admission pro hac vice in the Bankruptcy

Court for the Western District of Texas in the preceding twelve months. WHEREFORE, Applicant prays that this Court enter an order permitting the admission of Steven E. Nurenberg to the U.S. Bankruptcy Court Western District of Texas pro hac vice for these jointly administered cases, only. Respectfully submitted on Wednesday, February 15, 2012. MEUERS LAW FIRM, P.L. /s/Steven E. Nurenberg Steven E. Nurenberg Florida Bar No. 0808431 5395 Park Central Court Naples, FL 34109-5932 Telephone: (239) 513-9191 Facsimile: (239) 513-9677 snurenberg@meuerslawfirm.com Attorneys for Rio Queen Citrus, Inc., Eco-Farms Sales, Inc., Henry Avocado Corp., Gargiulo, Inc., C & R Fresh, LLC, Duckwall Fruit Co., Fresh Start Produce Sales and Sunriver Sales

CERTIFICATE OF SERVICE I HEREBY CERTIFY that this motion was filed with the Clerk of the Court and served via the Courts CM/ECF system upon all attorneys of record and parties receiving such service this Wednesday, February 15, 2012. By: /s/ Steven E. Nurenberg Steven E. Nurenberg

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