On July 30, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Woolslayer, Jeannie,
and
Lee C. Moore, Inc.,
for OTHER CONTRACT
in the District Court of Dallas County.
Preview
FILED
DALLAS COUNTY
8/7/2019 4:01 PM
FELICIA PITRE
DISTRICT CLERK
CAUSE NO. DC-19-10734 Rosa Delacerda
JEANNIE WOOLSLAYER, § IN THE DISTRICT COURT
§
Plaintzfif §
V. §
§
LEE C. MOORE, INC., A/K/A §
WOOLSLAYER COMPANIES, INC., §
RANDY WOLF, IN HIS CAPACITIES §
AS VOTING TRUSTEE FOR THE §
ROBERT T. WOOLSLAYER GST §
TRUST, VOTING TRUSTEE FOR THE §
HOMER WOOLSLAYER GST TRUST, §
298th JUDICIAL DISTRICT OF
VOTING TRUSTEE FOR THE JOHN §
WOOLSLAYER GST TRUST, AND §
VOTING TRUSTEE OF THE JOSEPH §
WOOLSLAYER GST TRUST, ROBERT §
T. WOOLSLAYER, HOMER §
WOOLSLAYER, JOHN §
WOOLSLAYER, AND JOSEPH §
WOOLSLAYER, INDIVIDUALLY, §
AND IN THEIR CAPACITIES AS CO- §
TRUSTEES OF THE WOOLSLAYER §
GST TRUSTS, §
§
Defendants. § DALLAS COUNTY, TEXAS
Motion in Support of Non-Resident Attorney’s
Mot_ion for Admi_ssion to Practice Pro Hac Vice
3
T0 The Honorable Judge of Said (Qourt:
The Undersigned, Matthew K. Good, an attorney licensed t0 practice in the courts
of the State 0f Texas, files this Motion in compliance with Rule XIX 0f the Rules
Governing Admission to the Bar of Texas and would show as follows:
1. I am personally acquainted with the applicant, David R. Cordell, seeking
permission to appear in this case and to participate in these proceedings and find him to
be a reputable attorney in all respects.
2. I have forwarded to him for his review and consultation the State Bar Act, the
State Bar Rules and the Texas Disciplinary Rules 0f Professional Conduct.
3. I recommend that the Motion filed by David R. Cordell be granted and that he be
granted permission to participate in the proceedings in this cause before this Honorable
Court.
Wherefore, Premises Considered, the undersigned respectfully moves that the
Motion for Admission t0 Practice Pro Hac Vice filed by David R. Cordell be granted and
for such other relief as justly entitled.
Dated: August 7, 2019
Respectfully submitted,
/s/Matthew K. Good
Matthew K. Good
State Bar No. 240993 14
Conner & Winters, LLP
1700 Pacific Avenue
Suite 2250
Dallas, Texas 75201
CERTIFICATE OF SERVICE
Ihereby certify that a true and correct copy of the foregoing document was served
7th
via e-mail on the day of August, 2019 upon counsel for Plaintiff, as follows:
Larry A. Flournoy, Jr., Esq.
e-mail: lflournovm '.,!FAtt0rnevs.com
JORDAN FLOURNOY LLP
10000 N. Central Expy., Suite 800
Dallas, Texas 75231
Chad T. McLain, Esq.
e-mail: cmclains'aJFAttornevs.com
Abbey Cohen, Esq.
e-mail: acohenr'c'uJFAttornevs.com
Matthew K. Good
/s/
Matthew K. Good
Document Filed Date
August 07, 2019
Case Filing Date
July 30, 2019
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED DALLAS COUNTY 8/7/2019 4:01 PM FELICIA PITRE DISTRICT CLERK CAUSE NO. DC-19-10734 Rosa Delacerda JEANNIE WOOLSLAYER, § IN THE DISTRICT COURT § Plaintzfif § V. § § LEE C. MOORE, INC., A/K/A § WOOLSLAYER COMPANIES, INC., § RANDY WOLF, IN HIS CAPACITIES § AS VOTING TRUSTEE FOR THE § ROBERT T. WOOLSLAYER GST § TRUST, VOTING TRUSTEE FOR THE § HOMER WOOLSLAYER GST TRUST, § 298th JUDICIAL DISTRICT OF VOTING TRUSTEE FOR THE JOHN § WOOLSLAYER GST TRUST, AND § VOTING TRUSTEE OF THE JOSEPH § WOOLSLAYER GST TRUST, ROBERT § T. WOOLSLAYER, HOMER § WOOLSLAYER, JOHN § WOOLSLAYER, AND JOSEPH § WOOLSLAYER, INDIVIDUALLY, § AND IN THEIR CAPACITIES AS CO- § TRUSTEES OF THE WOOLSLAYER § GST TRUSTS, § § Defendants. § DALLAS COUNTY, TEXAS Motion in Support of Non-Resident Attorney’s Mot_ion for Admi_ssion to Practice Pro Hac Vice 3 T0 The Honorable Judge of Said (Qourt: The Undersigned, Matthew K. Good, an attorney licensed t0 practice in the courts of the State 0f Texas, files this Motion in compliance with Rule XIX 0f the Rules Governing Admission to the Bar of Texas and would show as follows: 1. I am personally acquainted with the applicant, David R. Cordell, seeking permission to appear in this case and to participate in these proceedings and find him to be a reputable attorney in all respects. 2. I have forwarded to him for his review and consultation the State Bar Act, the State Bar Rules and the Texas Disciplinary Rules 0f Professional Conduct. 3. I recommend that the Motion filed by David R. Cordell be granted and that he be granted permission to participate in the proceedings in this cause before this Honorable Court. Wherefore, Premises Considered, the undersigned respectfully moves that the Motion for Admission t0 Practice Pro Hac Vice filed by David R. Cordell be granted and for such other relief as justly entitled. Dated: August 7, 2019 Respectfully submitted, /s/Matthew K. Good Matthew K. Good State Bar No. 240993 14 Conner & Winters, LLP 1700 Pacific Avenue Suite 2250 Dallas, Texas 75201 CERTIFICATE OF SERVICE Ihereby certify that a true and correct copy of the foregoing document was served 7th via e-mail on the day of August, 2019 upon counsel for Plaintiff, as follows: Larry A. Flournoy, Jr., Esq. e-mail: lflournovm '.,!FAtt0rnevs.com JORDAN FLOURNOY LLP 10000 N. Central Expy., Suite 800 Dallas, Texas 75231 Chad T. McLain, Esq. e-mail: cmclains'aJFAttornevs.com Abbey Cohen, Esq. e-mail: acohenr'c'uJFAttornevs.com Matthew K. Good /s/ Matthew K. Good