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.
Preview
CAUSE NO. 2015 47031
QRE OPERATING, LLC
Plaintiff, IN THE DISTRICT COURT OF
HARRIS COUNTY, TEXAS
ROGER D. PARSONS, IN HIS
CAPACITY AS TRUSTEE OF THE
LL&E ROYALTY TRUST, JUDICIAL DISTRICT
Defendant.
SWORN MOTION FOR ADMISSION PRO HAC VICE
STATE OF ILLINOIS
) ss
COUNTY OF COOK
Pursuant to Rule XIX of the Rules Goveming Admission to the Bar of TexasJ ohanna
Spellman respectfullyrequests permission to appear as counsel pro hac vicefor Plaintiff QRE
Operating, LLC(“Plaintiff inthiscase In support of this motion, I, being first duly swom on
oath, depose and state as follows:
Tama member of the law firm Latham &Watkins LLP (“Latham”), 330 North Wabash.
Avenue, Suite 2800, Chicago, IL 60611. I can be reached
via telephone at (312) 777
7039, via facsimileat (312) 993 9767, and via email at johanna.spellman@1w.com.
ThomasJ. Heiden (Tex. State Bar No. of Latham
& Watkins LLP has
appeared
as counsel for Plaintiff
in this case I will be associated
with Mr. Heiden in
these proceedings. Mr. Heiden’s office islocated at 330 North Wabash Avenue, Suite
2800, Chicago, Illinois, 60611He can be reachedv_ ia telephone
at (312) 876 6564, via
facsimileat (312) 993 9767, and via email at thomas.heiden@lw.com.
Pursuant to Rule XIX of the Rules Goveming Admission to the Bar of Texas, Mr.
Heiden is filing an accompanying
motion recommending
that I be granted permission to
participate in these proceedings.
I have not appeared in any cases or causes, or sought leave to appear
or participate in.
any cases
or causes of actionin Texas within the past two years.
was admitted
to the bar of the State of Illinois in 2007.As reflected in the Certificate
of Good Standing attachedas Exhibit hereto, Iam currently a n activemember
in good
standing of the Illinois Bar.
l amalso an active member in good standing in the U.S. Court of Appeals
for the
SeventhCircuit Court, the U.S. District Courts for the Northem District of Ilinois and
the U.S. District Court for the Eastem District of Michigan.
I 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 years.
I have not been denied admission to the courts of any State or any federal court during
the preceding five years.
1 am familiar with the State Bar Act, the State Bar Rules, and the Texas Disciplinary
Rules of Professional Conduct goveming the conduct of members of the State Bar of
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
accordance with Texas Govemment Code §82.0361 and Rule XIX of the Rules
Goveming Admission to the Bar of Texas, I have attached as Exhibit hereto proof
from the State Bar of Texasacknowledging
payment of the required filing fee
WHEREFORE, based on the foregoing, respectfully requestthat the Court enter a
Order
in the form of Exhibit 3, allowing _ to appear before this court pro hac vice for the
purpose of representing Plaintiffin connection with the above captioned matter.
a — a
4
By:
fohanna Spellman
Latham & Watkins LLP
330 North Wabash Avenue, Suite 2800
Chicago, IL 60611
Telephone: (312) 876-7700
Email: johanna.spellman@lw.com
Attorney for Plaintiff QRE Operating, LLC
STATE OF ILLINOIS
CITY OF CHICAGO IN COOK COUNTY
-
Subscribed and sworn to (or affirmed) before me on this ot day of November, 2015, by
I OHANNA SPELLMAN, who proved to me on the basis of satisfactory evidence to be the
person(s) who appeared before me.
Bar
SIGNATURE OF NOTARY PUBLIC
My commission expires:
Reeceeeaeasesacooeoreoosoors
e °
e "OFFICIAL SEAL”
e GLENDA D BURNS °
° Notary Public, State of Illinois °
e
e ires 02/08/16 $
Secccccccvoccocosesooesooees
—
Document Filed Date
November 06, 2015
Case Filing Date
August 12, 2015
Category
HOMEOWNERS ASSOCIATION
For full print and download access, please subscribe at https://www.trellis.law/.