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FILED
DALLAS COUNTY
8/12/2019 3:25 PM
FELICIA PITRE
DISTRICT CLERK
Jeffery White
CAUSE NO. DC-19-10734
JEANNIE WOOLSLAYER, § IN THE DISTRICT COURT
§
Plaintiff, §
v. §
§
LEE C. MOORE, INC., AIK/A § 298th JUDICIAL DISTRICT
WOOLSLAYER COMPANIES, |NC., §
RANDY WOLF, IN HIS CAPACITIES AS §
VOTING TRUSTEE FOR THE ROBERT T. §
WOOLSLAYER GST TRUST, VOTING §
TRUSTEE FOR THE HOMER §
WOOLSLAYER GST TRUST, 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, §
lNDIVIDUALLY, AND IN THEIR §
CAPACITIES AS CO-TRUSTEES OF THE §
WOOLSLAYER GST TRUSTS, §
§
Defendants. § DALLAS COUNTY, TEXAS
AMENDED UNOPPOSED MOTION FOR ADMISSION PRO HAC VICE
To the Honorable Judge of Said Court:
Pursuant to Rule XIX of the Rules Governing Admission to the Bar of Texas and
§82.0361 of Texas Government Code, the undersigned non-resident attorney. David R. Cordell
(“Movant”), respectfully moves for permission to participate in the proceedings in the above
cause and for such would show as follows:
A, Compliance Rule XIX of the Rules Governing Admission to the Bar of Texas
1. Office address, telephone number and telecopier number of non-resident Movant:
David R. Cordell, Esq.
Oklahoma State Bar No. 11272
Conner & Winters, LLP
Nine East Fourth Street
One Williams Center
Tulsa. OK 741 72
91 8—586—571 1
91 8-586-8330 (fax)
gggmgé.¥,@wia%§91§
AMENDED UNOPOSSED MOTION FOR ADMISSION PRO HAC VICE— Page 1
2. Name and State Bar number of an attorney licensed in Texas with whom the non-
resident attorney wil! be associated in the Texas proceedings and that attorney's office address,
telephone number and telecopier number:
Matthew Good. Esq.
Texas Bar No, 24099314
Conner & Winters, LLP
1700 Pacific Avenue. Suite 2250
Dallas, Texas 75201
214-217-8070
21 4-21 7-8861 fax
MG00d®§g§w.c0m
3. List of all cases and causes, including cause number and caption, in Texas courts in
which the non-resident attorney has appeared or sought leave to appear or participate within the
past two (2) years: None.
4. List of all jurisdictions in which the non—resident attorney is licensed, including federal
courts, and a statement that the non—resident attorney is or is not an active member in good
standing in each of those jurisdictions:
Oklahoma; Iowa; U.S. District Courts for the Northern, Eastern and Western Districts of
Oklahoma; U.S. Court of Appeals for the Tenth Circuit; U.S. Court. l am an active member in
good standing in these jurisdictions
5. Statement that the non—resident attorney has or has not been the subject of disciplinary
action by the Bar or courts of any jurisdiction in which the attorney is licensed within the
preceding five (5) years, and a description of any such disciplinary actions:
l have not been the subject of disciplinary action by the Bar or courts of any jurisdiction
in which | am licensed within the preceding five (5) years.
6. Statement that the non-resident attorney has or has not been denied admission to the
courts of any State or to any federal court during the preceding five (5) years:
AMENDED UNOPOSSED MOTION FOR ADMISSION PRO HAC VICE- Page 2
I have not been denied admission to the courts of any State or to any federal court
during the preceding five (5) years.
7. Statement that the non-resident attorney is 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 Bar of Texas and will at all times abide by and comply with the same so
long as such Texas proceeding is pending and said Movant has not withdrawn as counsel
therein.
I am familiar with the State Bar Act, the State Bar Rules and the Texas Disciplinary
Rules of Professional Conduct and will at all times abide by and comply with the same so long
as this proceeding is pending or l have withdrawn as counsel herein.
B. Com Nance with 82.0361 of Texa overnment Cod
Movant would show that, having appiied for admission and paid the required fee online,
Movant received the attached acknowledgement of same (Exhibit “A”), all in compliance with
§82.0361 of Texas Government Code.
[signature page follows]
AMENDED UNOPOSSED MOTION FOR ADMISSION PRO HAC VICE— Page 3
WHEREFORE, Premises Considered, Movant, David R. Cordell, a non-resident attorney
respectfully moves that Movant be admitted to practice in the above cause and for such other
and further relief to which Movant may be justly entitled.
Dated; 4
Respectfully submitted,
Oklahoma State Bar No 121272
Conner & Winters, LLP
Nine East Fourth Street
4000 One Williams Center
Tulsa. OK 741 72
91 8-586-5711
918- 586- 8330 (fax)
iisard 51%? {viwmm
VERIFICATION
l, David R. Cordell, have read the foregoing statements, and I swear and depose that
they are of my knowledge and are true and correct.
David R
@/W
CW
STATE 0F OKLAHOMA
vvv
COUNTY OF TULSA
BEFORE ME, the undersigned authority, appeared David R. Cordell. a person known to
me who, being duly sworn, deposed and said that the above and foregoing statements are true
and correct and of his own personal knowledge.
My Commissio
t
WM
No Punncmmmr
srftreyoroxuuw
AMENDED UNOPOSSED MOTION FOR ADMISSION PRO HAC VICE— Page 4
CERTIFICATE OF CONFERENCE
The Undersigned certifies that he has discussed the above Motion with counsel for
Plaintiff and this Motion is unopposed.
/s/ Matthew K. Good
Matthew K. Good
CERTIFICATE QF SERVICE
I hereby certify that a true and correct copy of the foregoing document was served via e-
mail on the 12th day of August, 2019, upon counsel for Plaintiff, as follows:
Larry A. Flournoy, Jr., Esq.
e-mail: Iflournox@JFAttornezs.com
Chad T. McLain. Esq.
e-mail: cmclain JFAttorne .co
Abbey Cohen, Esq.
g-mail: agohen@JFAttorggzs.com
JORDAN FLOURNOY LLP
10000 N. Central Expressway
Suite 800
Dallas. TX 75231
ATTORNEYS FOR JEANNIE WOOLSLAYER
/s/ Matthew K. Good
Matthew K. Good
AMENDED UNOPOSSED MOTION FOR ADMISSION PRO HAC VICE— Page 5
Preview
FILED DALLAS COUNTY 8/12/2019 3:25 PM FELICIA PITRE DISTRICT CLERK Jeffery White CAUSE NO. DC-19-10734 JEANNIE WOOLSLAYER, § IN THE DISTRICT COURT § Plaintiff, § v. § § LEE C. MOORE, INC., AIK/A § 298th JUDICIAL DISTRICT WOOLSLAYER COMPANIES, |NC., § RANDY WOLF, IN HIS CAPACITIES AS § VOTING TRUSTEE FOR THE ROBERT T. § WOOLSLAYER GST TRUST, VOTING § TRUSTEE FOR THE HOMER § WOOLSLAYER GST TRUST, 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, § lNDIVIDUALLY, AND IN THEIR § CAPACITIES AS CO-TRUSTEES OF THE § WOOLSLAYER GST TRUSTS, § § Defendants. § DALLAS COUNTY, TEXAS AMENDED UNOPPOSED MOTION FOR ADMISSION PRO HAC VICE To the Honorable Judge of Said Court: Pursuant to Rule XIX of the Rules Governing Admission to the Bar of Texas and §82.0361 of Texas Government Code, the undersigned non-resident attorney. David R. Cordell (“Movant”), respectfully moves for permission to participate in the proceedings in the above cause and for such would show as follows: A, Compliance Rule XIX of the Rules Governing Admission to the Bar of Texas 1. Office address, telephone number and telecopier number of non-resident Movant: David R. Cordell, Esq. Oklahoma State Bar No. 11272 Conner & Winters, LLP Nine East Fourth Street One Williams Center Tulsa. OK 741 72 91 8—586—571 1 91 8-586-8330 (fax) gggmgé.¥,@wia%§91§ AMENDED UNOPOSSED MOTION FOR ADMISSION PRO HAC VICE— Page 1 2. Name and State Bar number of an attorney licensed in Texas with whom the non- resident attorney wil! be associated in the Texas proceedings and that attorney's office address, telephone number and telecopier number: Matthew Good. Esq. Texas Bar No, 24099314 Conner & Winters, LLP 1700 Pacific Avenue. Suite 2250 Dallas, Texas 75201 214-217-8070 21 4-21 7-8861 fax MG00d®§g§w.c0m 3. List of all cases and causes, including cause number and caption, in Texas courts in which the non-resident attorney has appeared or sought leave to appear or participate within the past two (2) years: None. 4. List of all jurisdictions in which the non—resident attorney is licensed, including federal courts, and a statement that the non—resident attorney is or is not an active member in good standing in each of those jurisdictions: Oklahoma; Iowa; U.S. District Courts for the Northern, Eastern and Western Districts of Oklahoma; U.S. Court of Appeals for the Tenth Circuit; U.S. Court. l am an active member in good standing in these jurisdictions 5. Statement that the non—resident attorney has or has not been the subject of disciplinary action by the Bar or courts of any jurisdiction in which the attorney is licensed within the preceding five (5) years, and a description of any such disciplinary actions: l have not been the subject of disciplinary action by the Bar or courts of any jurisdiction in which | am licensed within the preceding five (5) years. 6. Statement that the non-resident attorney has or has not been denied admission to the courts of any State or to any federal court during the preceding five (5) years: AMENDED UNOPOSSED MOTION FOR ADMISSION PRO HAC VICE- Page 2 I have not been denied admission to the courts of any State or to any federal court during the preceding five (5) years. 7. Statement that the non-resident attorney is 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 Bar of Texas and will at all times abide by and comply with the same so long as such Texas proceeding is pending and said Movant has not withdrawn as counsel therein. I am familiar with the State Bar Act, the State Bar Rules and the Texas Disciplinary Rules of Professional Conduct and will at all times abide by and comply with the same so long as this proceeding is pending or l have withdrawn as counsel herein. B. Com Nance with 82.0361 of Texa overnment Cod Movant would show that, having appiied for admission and paid the required fee online, Movant received the attached acknowledgement of same (Exhibit “A”), all in compliance with §82.0361 of Texas Government Code. [signature page follows] AMENDED UNOPOSSED MOTION FOR ADMISSION PRO HAC VICE— Page 3 WHEREFORE, Premises Considered, Movant, David R. Cordell, a non-resident attorney respectfully moves that Movant be admitted to practice in the above cause and for such other and further relief to which Movant may be justly entitled. Dated; 4 Respectfully submitted, Oklahoma State Bar No 121272 Conner & Winters, LLP Nine East Fourth Street 4000 One Williams Center Tulsa. OK 741 72 91 8-586-5711 918- 586- 8330 (fax) iisard 51%? {viwmm VERIFICATION l, David R. Cordell, have read the foregoing statements, and I swear and depose that they are of my knowledge and are true and correct. David R @/W CW STATE 0F OKLAHOMA vvv COUNTY OF TULSA BEFORE ME, the undersigned authority, appeared David R. Cordell. a person known to me who, being duly sworn, deposed and said that the above and foregoing statements are true and correct and of his own personal knowledge. My Commissio t WM No Punncmmmr srftreyoroxuuw AMENDED UNOPOSSED MOTION FOR ADMISSION PRO HAC VICE— Page 4 CERTIFICATE OF CONFERENCE The Undersigned certifies that he has discussed the above Motion with counsel for Plaintiff and this Motion is unopposed. /s/ Matthew K. Good Matthew K. Good CERTIFICATE QF SERVICE I hereby certify that a true and correct copy of the foregoing document was served via e- mail on the 12th day of August, 2019, upon counsel for Plaintiff, as follows: Larry A. Flournoy, Jr., Esq. e-mail: Iflournox@JFAttornezs.com Chad T. McLain. Esq. e-mail: cmclain JFAttorne .co Abbey Cohen, Esq. g-mail: agohen@JFAttorggzs.com JORDAN FLOURNOY LLP 10000 N. Central Expressway Suite 800 Dallas. TX 75231 ATTORNEYS FOR JEANNIE WOOLSLAYER /s/ Matthew K. Good Matthew K. Good AMENDED UNOPOSSED MOTION FOR ADMISSION PRO HAC VICE— Page 5