UNITED STATES BANKRUPTCY COURT W ESTERN DISTRICT OF NEW YORK _____________________________________________ In Re NORSE ENERGY CORP. USA BK NO.

12-13685B APPLICATION BY TRUSTEE UNDER BANKRUPTCY RULE 2014 FOR ORDER APPROVING EM PLOYM ENT OF ATTORNEY AND ORDER

Debtor(s) _____________________________________________ TO THE COURT:

MARK S. W ALLACH, Trustee duly appointed and serving in the above case hereby requests an Order appointing the employment of the person or firm indicated below and submits the information recited below as required by Interim Rule 2014. SPECIFIC FACTS SHOW ING NECESSITY FOR SUCH EM PLOYM ENT: The Trustee was appointed in connection with the above-captioned case upon its conversion from Chapter 11 to Chapter 7. In 2010, a moratorium on high-volume hydraulic fracturing of oil and gas wells was put into effect by New York State pending completion of an Environmental Impact Statement pertaining to that activity. It appears that sufficient time has elapsed for the completion of the Environmental Impact Study and The W est Firm, PLLC (“W est”) desires to file an Article 78 Proceeding against various New York State governmental officials to compel the completion of the Environmental Impact Statement and W est has agreed to represent the Bankruptcy Estate’s interests on a pro bono basis in such proceeding as may be commenced. NAM E OF PERSON OR FIRM TO BE EM PLOYED: The W est Firm, PLLC REASON FOR SELECTION OF THIS PARTICULAR PERSON OR FIRM : Prior appointment of firm in Chapter 11 case and expertise of firm indicated in prior Application. PROFESSIONAL SERVICE TO BE RENDERED: Commence Article 78 Proceeding against various New York State governmental officials to compel the completion of Supplemental Generic Environmental Impact Statement relative to high volume hydraulic fracturing of oil and gas wells in New York State. ALL OF SUCH PERSON'S OR FIRM 'S CONNECTIONS W ITH THE DEBTOR, CREDITORS OR OTHER PARTIES IN INTEREST, OR THEIR RESPECTIVE ATTORNEYS AND ACCOUNTANTS, THE UNITED STATES TRUSTEE OR ANY PERSON EM PLOYED W ITH THE OFFICE OF THE UNITED STATES TRUSTEE: To the best of the Trustee’s knowledge, no member of the firm has any connection with the Debtor or creditors, or other parties in interest or their respective counsel except as set forth in the Declaration of Thomas S. W est, Esq. dated November 18, 2013. ALL COM PENSATION IS SUBJECT TO BANKRUPTCY COURT APPROVAL. DATED: November 18, 2013 /s/ Mark S. W allach ____________________________________ Trustee __________________________________________________________________________________________ ORDER Pursuant to 11 U.S.C. §327(a) and §328(a), the Trustee's employment of The W est Firm, PLLC of 677 Broadway, Albany, New York, 12207 to serve as attorney is approved. Compensation for the employment approved by this Order subject to Court approval. ____________________________________ U.S.B.J ORDERED:

Case 1-12-13685-CLB

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