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  • TONY EVANS, Sr., et al  vs. TASACOM REAL ESTATE, LLC, et alOTHER PERSONAL INJURY document preview
  • TONY EVANS, Sr., et al  vs. TASACOM REAL ESTATE, LLC, et alOTHER PERSONAL INJURY document preview
  • TONY EVANS, Sr., et al  vs. TASACOM REAL ESTATE, LLC, et alOTHER PERSONAL INJURY document preview
  • TONY EVANS, Sr., et al  vs. TASACOM REAL ESTATE, LLC, et alOTHER PERSONAL INJURY document preview
  • TONY EVANS, Sr., et al  vs. TASACOM REAL ESTATE, LLC, et alOTHER PERSONAL INJURY document preview
  • TONY EVANS, Sr., et al  vs. TASACOM REAL ESTATE, LLC, et alOTHER PERSONAL INJURY document preview
  • TONY EVANS, Sr., et al  vs. TASACOM REAL ESTATE, LLC, et alOTHER PERSONAL INJURY document preview
  • TONY EVANS, Sr., et al  vs. TASACOM REAL ESTATE, LLC, et alOTHER PERSONAL INJURY document preview
						
                                

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FILED 5/16/2023 2:14 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Treva Parker-Ayodele DEPUTY CAUSE NO. DC-21-04901 TONY EVANS, SR., and ARETHA EVANS, § individually and on behalf of their minor son, § T.E., deceased, FAITH TANKSLEY, on behalf § IN THE DISTRICT COURT OF of minor, T.E., III, individually and on behalf of § his father, T.E., deceased, and DEON § WILLIAMS, § DALLAS COUNTY, TEXAS § Plaintiffs, § § 162nd JUDICIAL DISTRICT vs. § § TASACOM REAL ESTATE, LLC, et al., § § Defendants. § UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF DAVID S. SAGER Comes now, David S. Sager (“Applicant”), and files this Unopposed Motion for Pro Hac Vice Admission (“Motion”) pursuant to Local Rule 4.03 and Rule XIX of the Rules Governing Admission to the Bar as counsel for Defendants Wyndham Hotels & Resorts, Inc., Wyndham Hotel Group, LLC, and Hawthorn Suites Franchising, Inc. (collectively, “Defendants”) and respectfully states: 1. Applicant is an attorney with the law firm DLA Piper LLP (US), 51 John F. Kennedy Parkway, Suite 120, Short Hills, New Jersey 07078-2704. Applicant’s telephone number is (973) 520-2550, his fax number is (973) 520-2551, and his email address is david.sager@us.dlapiper.com. 2. Applicant will be associated in this proceeding with Jason Hopkins, a Dallas attorney whose Texas State Bar Number is 24059969. Mr. Hopkins practices with the law firm of DLA Piper LLP (US), 1900 N. Pearl Street, Suite 2200, Dallas, Texas 75201. Mr. Hopkins’ telephone number is (214) 743-4500, his fax number is (214) 743-4545, and his email address is jason.hopkins@us.dlapiper.com. 3. Applicant has not sought admission pro hac vice in any court in Texas in the last two years. Applicant currently is admitted to practice pro hac vice in the following matters: In re Jane Doe Cases, MDL No. 19-0991 (MDL Civil Court, Harris Cnty., TX) (specifically, Jane Doe #8 v. Salesforce.com, Inc., et al., (Cause No. 2018CCV-61041-3); Jane Doe #7 v. Salesforce.com, Inc., et al. (Cause No. 2018-32490)). 4. Applicant is an active member in good standing of the bars of the states of New Jersey and New York, as well as the United States District Court for the Southern and Eastern Districts of New York; the District of New Jersey, the Eastern District of Michigan, and the United States Courts of Appeals for the Third and Eleventh Circuits. 5. Applicant has not been the subject of disciplinary actions by the Bar or the courts of any jurisdiction in which he is licensed in the past five years. 6. Applicant has not been denied admission to the courts of any state or to any federal court during the past five years. 7. Applicant attests that he is familiar with the State Bar Act, the State Bar Rules, the Texas Disciplinary Rules of Professional Conduct governing the conduct of members of the State Bar of Texas, the Harris County Local Rules, and the procedures of this Court. Applicant attests that he will at all times abide by and comply with these rules as long as the Texas proceeding is pending, and he has not withdrawn as counsel in the proceeding. 8. Pursuant to the Texas Rules Governing the Admission to the Bar of Texas, Rule XIX(a), Applicant has filed an application for admission pro hac vice with the Texas Board of Law Examiners and has paid the $250.00 filing fee. A true and correct copy of the Non-Resident Acknowledgment Letter from the Texas Board of Law Examiners to Applicant is attached to this Motion as Exhibit 1 and incorporated by reference. UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF DAVID S. SAGER 2 WHEREFORE, David S. Sager respectfully requests that the Court grant his Motion and enter an order allowing him to participate as attorney for Defendants Wyndham Hotels & Resorts, Inc., Wyndham Hotel Group, LLC, and Hawthorn Suites Franchising, Inc., in the above-titled and numbered cause of action. Date: May 16, 2023 Respectfully submitted, DLA PIPER LLP (US) /s/ David S. Sager 51 John F. Kennedy Parkway, Suite 120 Short Hills, New Jersey 07078 david.sager@us.dlapiper.com T: 973.520.2550 F: 973.520.2551 Jason Hopkins State Bar No. 24059969 jason.hopkins@us.dlapiper.com 1900 N. Pearl St. Suite 2200 Dallas, Texas 75201 T: 214.743.4500 F: 214.743.4545 Christopher B. Donovan State Bar No. 24097614 christopher.b.donovan@us.dlapiper.com 845 Texas Avenue, Suite 3800 Houston, Texas 77002 T: 713.425.8400 F: 713.425.8401 Counsel for Defendants Wyndham Hotels & Resorts, Inc., Wyndham Hotel Group, LLC, and Hawthorn Suites Franchising, Inc. UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF DAVID S. SAGER 3 CERTIFICATE OF CONFERENCE I certify that I conferred with counsel for Plaintiffs, who advised that the relief sought by this motion is not unopposed. /s/ Jason Hopkins Jason Hopkins CERTIFICATE OF SERVICE I hereby certify that, on May 16, 2023, a true and correct copy of the foregoing document was served on counsel of record in accordance with the Texas Rules of Civil Procedure via the court’s electronic filing system. /s/ Jason Hopkins Jason Hopkins UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF DAVID S. SAGER 4 EXHIBIT 1 Board of Law Examiners Appointed by the Supreme Court of Texas May 15, 2023 David S. Sager Via: E-Mail Acknowledgment Letter Non-Resident Attorney Fee According to Texas Government Code §82.0361, "a nonresident attorney requesting permission to participate in proceedings in a court in this state shall pay a fee of $250 for each case in which the attorney is requesting to participate." This Acknowledgement Letter serves as proof that the Board of Law Examiners has received $250 in connection with the following matter: Non-resident attorney: David S. Sager Case: DC-21-04901 Texas court or body: In the District Court of Dallas County, Texas, 162nd Judicial District After satisfying the fee requirement, a non-resident attorney shall file a motion in the Texas court or body in which the non-resident attorney is requesting permission to appear. The motion shall contain the information and statements required by Rule 19(a) of the Rules Governing Admission to the Bar of Texas. The motion must be accompanied by this Acknowledgment Letter and by a motion from a resident practicing Texas attorney that contains the statements required by Rule 19(b). The decision to grant or deny a non-resident attorney's motion for permission to participate in the proceedings in a particular cause is made by the Texas court or body in which it is filed. For more information, please see Rule 19 of the Rules Governing Admission to the Bar of Texas and §82.0361, of the Texas Government Code, which can be found on the Board's website. MAILING ADDRESS TELEPHONE: 512- 463-1621 - FACSIMILE: 512- 463-5300 STREET ADDRESS Post Office Box 13486 WEBSITE: www.ble.texas.gov 205 West 14th Street, Ste.500 Austin,Texas 78711-3486 Austin, Texas 78701 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Rose Chambers on behalf of Jason Hopkins Bar No. 24059969 rose.chambers@dlapiper.com Envelope ID: 75717905 Filing Code Description: Motion - Pro Hac Vice Filing Description: UNOPPOSED/DAVID SAGER Status as of 5/17/2023 3:55 PM CST Associated Case Party: TONY EVANS Name BarNumber Email TimestampSubmitted Status Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 5/17/2023 10:17:59 AM SENT Emily Taylor taylor@twlglawyers.com 5/17/2023 10:17:59 AM SENT Nuru Witherspoon litigation@twlglawyers.com 5/17/2023 10:17:59 AM SENT Associated Case Party: T. E. Name BarNumber Email TimestampSubmitted Status Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 5/17/2023 10:17:59 AM SENT Emily Taylor taylor@twlglawyers.com 5/17/2023 10:17:59 AM SENT Nuru Witherspoon litigation@twlglawyers.com 5/17/2023 10:17:59 AM SENT Associated Case Party: ARETHA EVANS Name BarNumber Email TimestampSubmitted Status Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 5/17/2023 10:17:59 AM SENT Emily Taylor taylor@twlglawyers.com 5/17/2023 10:17:59 AM SENT Nuru Witherspoon litigation@twlglawyers.com 5/17/2023 10:17:59 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Josimayra Diaz josi.diaz@dallascityhall.com 5/17/2023 10:17:59 AM SENT Luz Aguilar luz.aguilar@dallascityhall.com 5/17/2023 10:17:59 AM SENT RoseMarie Chambers rose.chambers@dlapiper.com 5/17/2023 10:17:59 AM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Rose Chambers on behalf of Jason Hopkins Bar No. 24059969 rose.chambers@dlapiper.com Envelope ID: 75717905 Filing Code Description: Motion - Pro Hac Vice Filing Description: UNOPPOSED/DAVID SAGER Status as of 5/17/2023 3:55 PM CST Case Contacts NURU WITHERSPOON witherspoon@twlglawyers.com 5/17/2023 10:17:59 AM SENT Sally Jones sally.jones@dlapiper.com 5/17/2023 10:17:59 AM SENT Ronald DHinds rdhinds@verizon.net 5/17/2023 10:17:59 AM SENT sherry M.faulkner sherry.faulkner@us.dlapiper.com 5/17/2023 10:17:59 AM SENT Associated Case Party: TASACOM REAL ESTATE, LLC Name BarNumber Email TimestampSubmitted Status Tasha LBarnes tbarnes@thompsoncoe.com 5/17/2023 10:17:59 AM SENT LISA V lvillasenor@thompsoncoe.com 5/17/2023 10:17:59 AM SENT Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 5/17/2023 10:17:59 AM SENT Christopher BDonovan Christopher.B.Donovan@dlapiper.com 5/17/2023 10:17:59 AM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 5/17/2023 10:17:59 AM SENT Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Name BarNumber Email TimestampSubmitted Status Jason Hopkins 24059969 jason.hopkins@dlapiper.com 5/17/2023 10:17:59 AM SENT Taylor Reed Taylor.reed@us.dlapiper.com 5/17/2023 10:17:59 AM SENT Christopher BDonovan Christopher.B.Donovan@dlapiper.com 5/17/2023 10:17:59 AM SENT Ronald DHinds rdhinds@verizon.net 5/17/2023 10:17:59 AM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Rose Chambers on behalf of Jason Hopkins Bar No. 24059969 rose.chambers@dlapiper.com Envelope ID: 75717905 Filing Code Description: Motion - Pro Hac Vice Filing Description: UNOPPOSED/DAVID SAGER Status as of 5/17/2023 3:55 PM CST Associated Case Party: MOHAMMADSADIQNOSHAHI Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 5/17/2023 10:17:59 AM SENT Eva DeLeon edeleon@thompsoncoe.com 5/17/2023 10:17:59 AM SENT Associated Case Party: MMAROOFUL CHOUDHURY Name BarNumber Email TimestampSubmitted Status Morgan Wells mwells@thompsoncoe.com 5/17/2023 10:17:59 AM SENT