On August 12, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
Parsons, Roger D (In His Capacity As Trustee Of The Ll & E Royalty Tr,
and
Bank Of New York Mellon,
Bank Of New York Mellon Trust Company N A,
Breitburn Energy Partners Lp,
Breitburn Management Company Llc,
Conocophillips Company,
Maverick Natural Resources, Llc As Trustee Of Ll&E Royalty Trust,
Qr Energy Lp,
Quantum Resources Management Llc,
Stifel Nicolaus & Company Inc,
Maverick Natural Resources Llc,
Parsons, Roger D (In His Capacity As Trustee Of The Ll & E Royalty Tr,
The Louisiana Land And Exploration Company Llc,
for HOMEOWNERS ASSOCIATION
in the District Court of Harris County.
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CAUSE NO. 2015-47031
QRE OPERATING, LLC, IN THE DISTRICT COURT OF
Plaintiff/Counter-Defendant,
v. HARRIS COUNTY, TEXAS
ROGER D. PARSONS, IN HIS
CAPACITY AS TRUSTEE OF THE
LL&E ROYALTY TRUST,
§
§
§
§
§
§
§
§
:
§ 133™ JUDICIAL DISTRICT
Defendant/Counter-Plaintiff,
SWORN MOTION FOR ADMISSION PRO HAC VICE
STATE OF MICHIGAN )
COUNTY OF OAKLAND}
Pursuant to Rule XIX of the Rules Governing Admission to the Bar of Texas, Marjan
Neceski respectfully requests permission to appear as counsel pro hac vice for Defendant Roger
D. Parsons, in his capacity as Trustee of the LL&E Royalty Trust (“Defendant”) in this case. In
support of this motion, I, being first duly sworn on oath, depose and state as follows:
1, I am a member of the law firm of SIMON, PLC Attorneys & Counselors
(SIMON PLC”), 37000 Woodward Avenue, Suite 250, Bloomfield Hills, MI 48304. 1 can be
reached via telephone at (248) 720-0290, via facsimile at (248) 720-0291, and via e-mail at
maneceski@simonattys.com.
2, David A. Stephan (Texas State Bar No. 19143900) of SIMON PLC Attorneys &
Counselors has appeared as counsel for Defendant in this case. I will be associated with Mr.
Stephan in these proceedings. Mr. Stephan’s office is located at 10000 North CentralExpressway, Dallas, TX 75231. He can be reached via telephone at (214) 890-4085, via
facsimile at (214) 890-9249, and via e-mail at dstephan@simonattys.com.
3. Pursuant to Rule XIX of the Rules Governing Admission to the Bar of Texas, Mr.
Stephan is filing an accompanying motion recommending that I be granted permission to
participate in these proceedings.
4. I have not appeared in any cases or causes, or sought leave to appear or participate
in any cases or causes of action, in Texas within the past two (2) years.
5. T was admitted to the bar of the State of New York on or about April 16, 1996.
As reflected in the Certificate of Good Standing attached as Exhibit I hereto, I am currently an
active member in good standing of the New York Bar.
6. I was admitted to the bar of the State of Michigan on or about February 24, 2006.
As reflected in the Certificate of Good Standing attached as Exhibit 2 hereto, I am currently an
active member in good standing of the Michigan Bar.
7. I was admitted to the bar of the State of Ohio on or about July 10, 2007. As
reflected in the Certificate of Good Standing attached as Exhibit 3 hereto, I am currently an
active member in good standing of the Ohio Bar.
8. T have not been the subject of disciplinary action by the Bar or Courts of any
jurisdiction in which I am licensed within the preceding five (5) years.
9. Ihave not been denied admission to the Courts of any State or any Federal Court
during the preceding five (5) years.
10. I am familiar with the State Bar Act, the State Bar Rules, and the Texas
Disciplinary Rules of Professional Conduct governing the conduct of members of the State Barof Texas, and will at all times abide by and comply with the same so long as this proceeding is
pending and I have not withdrawn as counsel therein.
11. In accordance with Texas Government Code §82.0361 and Rule XIX of the Rules
Governing Admission to the Bar of Texas, I have attached as Exhibit 4 hereto, proof from the
State Bar of Texas acknowledging payment of the required filing fee.
WHEREFORE, based on the foregoing, I respectfully request that the Court enter an
Order in the form of Exhibit 5, allowing me to appear before this court pro hac vice for the
purpose of representing Defendant in connection with the above-captioned matter.
Respectfully submitted,
SIMON PLC
Attorneys & Counselors
Dated: January 14, 2016 By: — /s/Marjan Neceski
Marjan Neceski
37000 Woodward Avenue, Suite 250
Bloomfield Hills, Michigan 48304
(248) 720-0290 Telephone
(248) 720-0291 Facsimile
muneceski@simonattys.com
ATTORNEYS FOR DEFENDANT
LL&E Royalty Trust, by Reger Parsons
Subscribed and sworn to before me
this /4/#Iday of January, 2016
THERESA BoosmRow
Arson) Potatanre— NOTARY PUBLIC, STATE OF
Theresd Boostrom, Notary Public uvcontmaaion oe 0
Jun 40, 2018
Oakland County, Michigan AGTINGINCOUNTYOF 00.474 a of
My commission expires: 6/10/18
Acting in Oakland County, Michigani
I
CERTIFICATE OF SERVICE |
|
This is to certify that a true and correct copy of the foregoing SWORN MOTION FOR
|
|
ADMISSION PRO HAC VICE was served pursuant to the Texas Rules of Civil Procedures on [
the following parties on the 14" day of January, 2016:
Thomas J. Heiden
Latham & Watkins, LLP
330 North Wabash Avenue, Suite 2800
Chicago, Illinois 60611
Johanna Spellman
Latham & Watkins, LLP
330 North Wabash Avenue, Suite 2800
Chicago, Illinois 60611
¢s/ Marjan Neceski
Marjan Neceski, Esq.
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CAUSE NO. 2015-47031 QRE OPERATING, LLC, IN THE DISTRICT COURT OF Plaintiff/Counter-Defendant, v. HARRIS COUNTY, TEXAS ROGER D. PARSONS, IN HIS CAPACITY AS TRUSTEE OF THE LL&E ROYALTY TRUST, § § § § § § § § : § 133™ JUDICIAL DISTRICT Defendant/Counter-Plaintiff, SWORN MOTION FOR ADMISSION PRO HAC VICE STATE OF MICHIGAN ) COUNTY OF OAKLAND} Pursuant to Rule XIX of the Rules Governing Admission to the Bar of Texas, Marjan Neceski respectfully requests permission to appear as counsel pro hac vice for Defendant Roger D. Parsons, in his capacity as Trustee of the LL&E Royalty Trust (“Defendant”) in this case. In support of this motion, I, being first duly sworn on oath, depose and state as follows: 1, I am a member of the law firm of SIMON, PLC Attorneys & Counselors (SIMON PLC”), 37000 Woodward Avenue, Suite 250, Bloomfield Hills, MI 48304. 1 can be reached via telephone at (248) 720-0290, via facsimile at (248) 720-0291, and via e-mail at maneceski@simonattys.com. 2, David A. Stephan (Texas State Bar No. 19143900) of SIMON PLC Attorneys & Counselors has appeared as counsel for Defendant in this case. I will be associated with Mr. Stephan in these proceedings. Mr. Stephan’s office is located at 10000 North CentralExpressway, Dallas, TX 75231. He can be reached via telephone at (214) 890-4085, via facsimile at (214) 890-9249, and via e-mail at dstephan@simonattys.com. 3. Pursuant to Rule XIX of the Rules Governing Admission to the Bar of Texas, Mr. Stephan is filing an accompanying motion recommending that I be granted permission to participate in these proceedings. 4. I have not appeared in any cases or causes, or sought leave to appear or participate in any cases or causes of action, in Texas within the past two (2) years. 5. T was admitted to the bar of the State of New York on or about April 16, 1996. As reflected in the Certificate of Good Standing attached as Exhibit I hereto, I am currently an active member in good standing of the New York Bar. 6. I was admitted to the bar of the State of Michigan on or about February 24, 2006. As reflected in the Certificate of Good Standing attached as Exhibit 2 hereto, I am currently an active member in good standing of the Michigan Bar. 7. I was admitted to the bar of the State of Ohio on or about July 10, 2007. As reflected in the Certificate of Good Standing attached as Exhibit 3 hereto, I am currently an active member in good standing of the Ohio Bar. 8. T have not been the subject of disciplinary action by the Bar or Courts of any jurisdiction in which I am licensed within the preceding five (5) years. 9. Ihave not been denied admission to the Courts of any State or any Federal Court during the preceding five (5) years. 10. I am familiar with the State Bar Act, the State Bar Rules, and the Texas Disciplinary Rules of Professional Conduct governing the conduct of members of the State Barof Texas, and will at all times abide by and comply with the same so long as this proceeding is pending and I have not withdrawn as counsel therein. 11. In accordance with Texas Government Code §82.0361 and Rule XIX of the Rules Governing Admission to the Bar of Texas, I have attached as Exhibit 4 hereto, proof from the State Bar of Texas acknowledging payment of the required filing fee. WHEREFORE, based on the foregoing, I respectfully request that the Court enter an Order in the form of Exhibit 5, allowing me to appear before this court pro hac vice for the purpose of representing Defendant in connection with the above-captioned matter. Respectfully submitted, SIMON PLC Attorneys & Counselors Dated: January 14, 2016 By: — /s/Marjan Neceski Marjan Neceski 37000 Woodward Avenue, Suite 250 Bloomfield Hills, Michigan 48304 (248) 720-0290 Telephone (248) 720-0291 Facsimile muneceski@simonattys.com ATTORNEYS FOR DEFENDANT LL&E Royalty Trust, by Reger Parsons Subscribed and sworn to before me this /4/#Iday of January, 2016 THERESA BoosmRow Arson) Potatanre— NOTARY PUBLIC, STATE OF Theresd Boostrom, Notary Public uvcontmaaion oe 0 Jun 40, 2018 Oakland County, Michigan AGTINGINCOUNTYOF 00.474 a of My commission expires: 6/10/18 Acting in Oakland County, Michigani I CERTIFICATE OF SERVICE | | This is to certify that a true and correct copy of the foregoing SWORN MOTION FOR | | ADMISSION PRO HAC VICE was served pursuant to the Texas Rules of Civil Procedures on [ the following parties on the 14" day of January, 2016: Thomas J. Heiden Latham & Watkins, LLP 330 North Wabash Avenue, Suite 2800 Chicago, Illinois 60611 Johanna Spellman Latham & Watkins, LLP 330 North Wabash Avenue, Suite 2800 Chicago, Illinois 60611 ¢s/ Marjan Neceski Marjan Neceski, Esq.