Motion-Secondary: Emilio Tucci, Marta Tucci v. Ashland, Llc. F/K/A Ashland, Inc.,, Basf Corporation, Individually And As Successor In Interest To Inmont Corporation And D/B/A Basf-Inmont, Successor In Interest To And D/B/A Glasurit And R-M Company F/K/A Rinshed Mason Company, E.I. Du Pont De Nemours & Company, Icc Chemical Corporation, Ppg Industries, Inc., Shell Oil Company, Sunoco, Llc F/K/A Sunoco, Inc. (R&M), Texaco, Inc., Univar Usa, Inc. F/K/A Chemcentral Corp., And Van Waters & Rodgers, Inc.

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                                FILED: NEW YORK COUNTY CLERK 05/17/2023 01:43 PM                                              INDEX NO. 159245/2022
NYSCEF DOC. NO. 110                                                                    RECEIVED NYSCEF: 05/17/2023




          SUPREME COURT OF THE STATE OF NEW YORK
          COUNTY OF NEW YORK


          EMILIO and MARTA TUCCI,                                             Index No. 159245/2022

                                                                              AFFIRMATION OF
                                                                              WILLIAM PERRELLI,
                                                                              ESQ. IN SUPPORT OF
                                                                              APPLICATION FOR
                                                Plaintiff(s),                 ADMISSION PRO HAC
                                                                              VICE
                         v.

          ASHLAND, LLC, et al.,


                                                Defendants.



                 William Perrelli, Esq., an attorney duly admitted to practice law before the Courts of

          this State, affirms, under the penalties of perjury pursuant to CPLR § 2106 as follows:

                 1.      I am an attorney at law duly licensed to practice in the State of New York and an

         associate of the firm Maron Marvel, attorneys for defendant, Sunoco, LLC f/k/a Sunoco, Inc.

          (R&M) (hereinafter “Sunoco” or “Defendant”) in the above-captioned action. As such, I am

         fully familiar with the facts and circumstances stated herein as well as all prior pleadings and

         proceedings in this matter.

                 2.      I submit this affirmation in support of defendant Sunoco’s application for an

         Order: (1) pursuant to 22 N.Y.C.R.R. § 520.11, admitting Chad D. Mountain, Esq. to practice

         before this Court pro hac vice on behalf of defendant Sunoco; and (2) for such other and further

          relief as the Court deems just and proper.

                 3.      As set forth in the annexed affidavit of Chad D. Mountain, Esq. attached hereto as

          Exhibit “A”, he is a member of the firm Maron Marvel.




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FILED: NEW YORK COUNTY CLERK 05/17/2023 01:43 PM                                               INDEX NO. 159245/2022
NYSCEF DOC. NO. 110                                                                     RECEIVED NYSCEF: 05/17/2023




                 4.      Mr. Mountain received the degree of Juris Doctor from Villanova University of

          School of Law in 2000. He was admitted to practice in the Commonwealth of Pennsylvania in

          2001 and State of New Jersey in 2000. In addition, Mr. Mountain is admitted in the United

          States District Courts for the Eastern District of Pennsylvania, the District of New Jersey, and the

          Eastern District of Michigan, as well as the United States Court of Appeals for the Third Circuit.

          He is a member in good standings of these courts. Copies of Mr. Mountain’s Certificates of

         Good Standing for the Commonwealth of Pennsylvania and State of New Jersey are attached

          hereto collectively Exhibit “B”.

                 5.      This is a benzene exposure matter. Sunoco is requesting that, by virtue of Mr.

          Mountain’s experience with benzene exposure matters, as well as his relationship with Sunoco,

          Mr. Mountain’s be admitted pro hac vice to take part in representing Sunoco in this lawsuit.

                 6.      Authorization is sought to admit Mr. Mountain to practice pro hac vice before this

          Court to participate in all aspects of the remaining discovery and trial of this matter. The period

          for which authorization is sought is to the date of resolution of all claims against Sunoco or the

         date of entry of judgment by this court following trial of this matter, whichever occurs first.

                 7.      I recommend the admission of Mr. Mountain to practice before this Court pro hac

         vice on behalf of defendant Sunoco without reservations.

                 WHEREFORE, Sunoco respectfully requests that this Court grant its application

          admitting Chad D. Mountain, Esq. to practice before this Court pro hac vice on behalf of




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FILED: NEW YORK COUNTY CLERK 05/17/2023 01:43 PM                                              INDEX NO. 159245/2022
NYSCEF DOC. NO. 110                                                                     RECEIVED NYSCEF: 05/17/2023




          defendant Sunoco, LLC f/k/a Sunoco, Inc. (R&M), together with such other and further relief as

         this Court may deem just and proper.


         DATED:         Jersey City, New Jersey
                        May 17, 2023


                                                              /s/ William P. Perrelli

                                                            William Perrelli, Esq.




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