Preview
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