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CAUSE NO. DC-23-07534
BERNARD TUBEILEH and SINOSTAR § IN THE DISTRICT COURT OF
INVESTMENTS LLC,
§§§§§§§§§
Plaintiffs,
V.
DALLAS COUNTY, TEXAS
GLOBAL OIL & GAS TEXAS, LLC, and
GLOBAL OIL & GAS FIELDS
OKLAHOMA LLC,
Defendants. 68th JUDICIAL DISTRICT
ORDER T0 SHOW CAUSE
On May 6, 2024, Plaintiffs Bernard Tueileh and Sinostar Investments LLC's filed
their Motion to Show Cause, for Order Revoking Pro Hac Vice Admission, and for
Sanctions, and Brief in Support (the “Motion") against Defendants Global Oil & Gas
Texas, LLC and Global Oil & Gas Fields Oklahoma, LLC (collectively “Defendants”). The
Motion alleges that Defendants are violating the applicable Texas rules, the Court’s
January 12, 2024 Order, and the Court’s Order, as follows:
1. Defendants paid a material witness, Dr. Detlef Mader, for his favorable testimony
and prevented him from making any statements to Bernard Tubeileh in violation of
Rule 3.04(a) and (b) of the Texas Disciplinary Rules of Professional Conduct;
Defendants’ corporate representative, Oliver Krautscheid, testified falsely and non-
responsively and feigned his lack of command of the English language to waste
time, in violation of Rules 215.1(b)(2)(B), 215.1(c), and 215.3 of the Texas Rules
of Civil Procedure, Section 37.03(a)(1) of the Texas Penal Code; and Article lll,
Section 17 of the Texas Lawyer’s Creed;
Defendants failed to produce responsive documents, including Dr. Mader’s emails
and text messages, within their possession, custody, or control and produced tens
of thousands of pages of non-responsive documents in violation of the Court’s
January 12, 2024 and _ Orders and Rule 215.3 of the Texas Rules of Civil
Procedure;
Defendants’ counsel instructed Mr. Krautscheid, a German national without
permission to work in the United States, to instruct Defendants’ employee, Lori
Order to Show Cause Page 1 of 3
Land, not to pay the amounts owed under the loans made the basis of Plaintiffs'
Couns VI and VII, in an act of illegal interference, in violation of 8 U.S.C. § 1324(a)
et seq.;
5. Defendants and Mr. Krautscheid committed spoliaion by “losing" the May 5, 2023
appointments of Mr. Krautscheid as Defendant’ Manager, crucial documents
ordered to be produced by the Court in its January 12, 2024 and _ Orders;
6. Defendants’ counterclaim 1) contains allegations that are provably false, 2) was
filed without a good-faith belief of those allegations, and 3) has no supporting fact
witnesses for the false allegations, in violation of Texas Rules of Civil Procedure
13 and 215.3 and Rules 3.01 and 3.02 of the Texas Disciplinary Rules of
Professional Conduct;
7. Defendants’ counsel presented three Oklahoma courts with invalid, improper ex-
parte subpoenas and represented to those Oklahoma courts that they were valid
subpoenas issued in compliance with the Texas rules and this Court’s authority,
and subsequently served unknowing Oklahoma residents with these invalid
Oklahoma subpoenas;
8. Defendants failed to provide compliant verifications for their interrogatory answers,
in violation of the Court’s _ Order;
9. Defendants repeatedly violated the Texas Rules of Civil Procedure requiring filing
and service in violation of Rules 21, 21a, and 176.5 of the Texas Rules of Civil
Procedure;
10. Defendants’ failures to comply with the Texas Rules of Civil Procedure, the Texas
Lawyer’s Creed, Texas Disciplinary Rules of Professional Conduct, and the Court’s
Orders (including the January 12, 2024 Order and the _ Order) are an abuse
of the discovery process. Defendants’ failures to comply have been made for the
purpose of delay, in violation of Rule 215.3 of the Texas Rules of Civil Procedure.
Plaintiffs further ask that the Court revoke the pro hac vice admissions of
Defendants’ counsel Joshua Fellenbaum, Jeffrey Sindelar, and Michael Zellers in
connection with the above-referenced conduct.
Order to Show Cause Page 2 of 3
The Motion is set for hearing at on , 2024 (the
“Hearing”).
The Court hereby ORDERS that each of the following appear at the Hearing,
provide testimony, and show cause why they should not be held in contempt of
court and have their pro hac vice admission revoked (as applicable):
1. A corporate representative for Global Oil & Gas Fields Oklahoma LLC
with knowledge regarding the matters set forth in the Motion and
above;
2. A corporate representative for Global Oil & Gas Texas, LLC with
knowledge regarding the matters set forth in the Motion and above;
Joshua Fellenbaum
Jeffrey Sindelar
Christopher Staine
Michael Zellers
Tim Gallegly (Defendants’ Oklahoma counsel), and
Deric McClellan (Defendants’ Oklahoma counsel).
Defendants are further ORDERED to provide a copy of this Order to Tim Gallegly
and Deric McClellan (Defendants’ Oklahoma counsel) and file proof of service of same.
Signed
Judge Presiding
Order to Show Cause Page 3 of 3
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.
Michelle Logan on behalf of Courtney Bowline
Bar No. 24055206
mlogan@brianlauten.com
Envelope ID: 87571335
Filing Code Description: Non-Signed Proposed Order/Judgment
Filing Description: PROPOSED ORDER FOR SHOW CAUSE
Status as of 5/9/2024 2:42 PM CST
Associated Case Party: BERNARD TUBEILEH
Name BarNumber Email TimestampSubmitted Status
Brian PLauten blauten@brianlauten.com 5/9/2024 2:19:08 PM SENT
Michelle Logan mlogan@brianlauten.com 5/9/2024 2:19:08 PM SENT
Kaylee Vanstory kvanstory@brianlauten.com 5/9/2024 2:19:08 PM SENT
Courtney GBowline cbowline@brianlauten.com 5/9/2024 2:19:08 PM SENT
Associated Case Party: GLOBAL OIL & GAS TEXAS LLC
Name BarNumber Email TimestampSubmitted Status
Christopher Staine christopher.staine@crowedunlevy.com 5/9/2024 2:19:08 PM SENT
Michael C.Ze||ers michael.zellers@tuckerellis.com 5/9/2024 2:19:08 PM SENT
Jeffrey C.Sindelar Jr. jeffrey.sindelar@tuckerellis.com 5/9/2024 2:19:08 PM SENT
Melissa Z.Kelly Melissa.Kelly@tuckerellis.com 5/9/2024 2:19:08 PM SENT
WILLIAM STAVOLE MELISSA.KELLY@TUCKERELLIS.COM 5/9/2024 2:19:08 PM SENT
William Stavole william.stavole@tuckerellis.com 5/9/2024 2:19:08 PM SENT
Christen Wilk Christen.Wilk@tuckerellis.com 5/9/2024 2:19:08 PM SENT
Chad M.Eggspuehler Chad.Eggspuehler@tuckerellis.com 5/9/2024 2:19:08 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Gene AHamm ||
ghamm@hammfirm.com 5/9/2024 2:19:08 PM SENT
John PMartin jmartin@hammfirm.com 5/9/2024 2:19:08 PM SENT
Stephanie Rzepka stephanie.rzepka@tuckerellis.com 5/9/2024 2:19:08 PM 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.
Michelle Logan on behalf of Courtney Bowline
Bar No. 24055206
mlogan@brianlauten.com
Envelope ID: 87571335
Filing Code Description: Non-Signed Proposed Order/Judgment
Filing Description: PROPOSED ORDER FOR SHOW CAUSE
Status as of 5/9/2024 2:42 PM CST
Case Contacts
Stephanie Rzepka stephanie.rzepka@tuckerellis.com 5/9/2024 2:19:08 PM SENT
Sarah Prince sarah.prince@crowedunlevy.com 5/9/2024 2:19:08 PM SENT
Joshua Fellenbaum joshua.fellenbaum@tuckerellis.com 5/9/2024 2:19:08 PM SENT
Elizabeth Palmer empalmer9009@gmail.com 5/9/2024 2:19:08 PM SENT
Associated Case Party: GLOBAL OIL & GAS FIELDS OKLAHOMA LLC
Name BarNumber Email TimestampSubmitted Status
Chad M.Eggspuehler Chad.Eggspuehler@tuckerellis.com 5/9/2024 2:19:08 PM SENT
Associated Case Party: WILLIAM J. STAVOLE
Name BarNumber Email Timestam pSubmitted Status
William Stavole william.stavole@tuckerellis.com 5/9/2024 2:19:08 PM SENT
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CAUSE NO. DC-23-07534 BERNARD TUBEILEH and SINOSTAR § IN THE DISTRICT COURT OF INVESTMENTS LLC, §§§§§§§§§ Plaintiffs, V. DALLAS COUNTY, TEXAS GLOBAL OIL & GAS TEXAS, LLC, and GLOBAL OIL & GAS FIELDS OKLAHOMA LLC, Defendants. 68th JUDICIAL DISTRICT ORDER T0 SHOW CAUSE On May 6, 2024, Plaintiffs Bernard Tueileh and Sinostar Investments LLC's filed their Motion to Show Cause, for Order Revoking Pro Hac Vice Admission, and for Sanctions, and Brief in Support (the “Motion") against Defendants Global Oil & Gas Texas, LLC and Global Oil & Gas Fields Oklahoma, LLC (collectively “Defendants”). The Motion alleges that Defendants are violating the applicable Texas rules, the Court’s January 12, 2024 Order, and the Court’s Order, as follows: 1. Defendants paid a material witness, Dr. Detlef Mader, for his favorable testimony and prevented him from making any statements to Bernard Tubeileh in violation of Rule 3.04(a) and (b) of the Texas Disciplinary Rules of Professional Conduct; Defendants’ corporate representative, Oliver Krautscheid, testified falsely and non- responsively and feigned his lack of command of the English language to waste time, in violation of Rules 215.1(b)(2)(B), 215.1(c), and 215.3 of the Texas Rules of Civil Procedure, Section 37.03(a)(1) of the Texas Penal Code; and Article lll, Section 17 of the Texas Lawyer’s Creed; Defendants failed to produce responsive documents, including Dr. Mader’s emails and text messages, within their possession, custody, or control and produced tens of thousands of pages of non-responsive documents in violation of the Court’s January 12, 2024 and _ Orders and Rule 215.3 of the Texas Rules of Civil Procedure; Defendants’ counsel instructed Mr. Krautscheid, a German national without permission to work in the United States, to instruct Defendants’ employee, Lori Order to Show Cause Page 1 of 3 Land, not to pay the amounts owed under the loans made the basis of Plaintiffs' Couns VI and VII, in an act of illegal interference, in violation of 8 U.S.C. § 1324(a) et seq.; 5. Defendants and Mr. Krautscheid committed spoliaion by “losing" the May 5, 2023 appointments of Mr. Krautscheid as Defendant’ Manager, crucial documents ordered to be produced by the Court in its January 12, 2024 and _ Orders; 6. Defendants’ counterclaim 1) contains allegations that are provably false, 2) was filed without a good-faith belief of those allegations, and 3) has no supporting fact witnesses for the false allegations, in violation of Texas Rules of Civil Procedure 13 and 215.3 and Rules 3.01 and 3.02 of the Texas Disciplinary Rules of Professional Conduct; 7. Defendants’ counsel presented three Oklahoma courts with invalid, improper ex- parte subpoenas and represented to those Oklahoma courts that they were valid subpoenas issued in compliance with the Texas rules and this Court’s authority, and subsequently served unknowing Oklahoma residents with these invalid Oklahoma subpoenas; 8. Defendants failed to provide compliant verifications for their interrogatory answers, in violation of the Court’s _ Order; 9. Defendants repeatedly violated the Texas Rules of Civil Procedure requiring filing and service in violation of Rules 21, 21a, and 176.5 of the Texas Rules of Civil Procedure; 10. Defendants’ failures to comply with the Texas Rules of Civil Procedure, the Texas Lawyer’s Creed, Texas Disciplinary Rules of Professional Conduct, and the Court’s Orders (including the January 12, 2024 Order and the _ Order) are an abuse of the discovery process. Defendants’ failures to comply have been made for the purpose of delay, in violation of Rule 215.3 of the Texas Rules of Civil Procedure. Plaintiffs further ask that the Court revoke the pro hac vice admissions of Defendants’ counsel Joshua Fellenbaum, Jeffrey Sindelar, and Michael Zellers in connection with the above-referenced conduct. Order to Show Cause Page 2 of 3 The Motion is set for hearing at on , 2024 (the “Hearing”). The Court hereby ORDERS that each of the following appear at the Hearing, provide testimony, and show cause why they should not be held in contempt of court and have their pro hac vice admission revoked (as applicable): 1. A corporate representative for Global Oil & Gas Fields Oklahoma LLC with knowledge regarding the matters set forth in the Motion and above; 2. A corporate representative for Global Oil & Gas Texas, LLC with knowledge regarding the matters set forth in the Motion and above; Joshua Fellenbaum Jeffrey Sindelar Christopher Staine Michael Zellers Tim Gallegly (Defendants’ Oklahoma counsel), and Deric McClellan (Defendants’ Oklahoma counsel). Defendants are further ORDERED to provide a copy of this Order to Tim Gallegly and Deric McClellan (Defendants’ Oklahoma counsel) and file proof of service of same. Signed Judge Presiding Order to Show Cause Page 3 of 3 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. Michelle Logan on behalf of Courtney Bowline Bar No. 24055206 mlogan@brianlauten.com Envelope ID: 87571335 Filing Code Description: Non-Signed Proposed Order/Judgment Filing Description: PROPOSED ORDER FOR SHOW CAUSE Status as of 5/9/2024 2:42 PM CST Associated Case Party: BERNARD TUBEILEH Name BarNumber Email TimestampSubmitted Status Brian PLauten blauten@brianlauten.com 5/9/2024 2:19:08 PM SENT Michelle Logan mlogan@brianlauten.com 5/9/2024 2:19:08 PM SENT Kaylee Vanstory kvanstory@brianlauten.com 5/9/2024 2:19:08 PM SENT Courtney GBowline cbowline@brianlauten.com 5/9/2024 2:19:08 PM SENT Associated Case Party: GLOBAL OIL & GAS TEXAS LLC Name BarNumber Email TimestampSubmitted Status Christopher Staine christopher.staine@crowedunlevy.com 5/9/2024 2:19:08 PM SENT Michael C.Ze||ers michael.zellers@tuckerellis.com 5/9/2024 2:19:08 PM SENT Jeffrey C.Sindelar Jr. jeffrey.sindelar@tuckerellis.com 5/9/2024 2:19:08 PM SENT Melissa Z.Kelly Melissa.Kelly@tuckerellis.com 5/9/2024 2:19:08 PM SENT WILLIAM STAVOLE MELISSA.KELLY@TUCKERELLIS.COM 5/9/2024 2:19:08 PM SENT William Stavole william.stavole@tuckerellis.com 5/9/2024 2:19:08 PM SENT Christen Wilk Christen.Wilk@tuckerellis.com 5/9/2024 2:19:08 PM SENT Chad M.Eggspuehler Chad.Eggspuehler@tuckerellis.com 5/9/2024 2:19:08 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Gene AHamm || ghamm@hammfirm.com 5/9/2024 2:19:08 PM SENT John PMartin jmartin@hammfirm.com 5/9/2024 2:19:08 PM SENT Stephanie Rzepka stephanie.rzepka@tuckerellis.com 5/9/2024 2:19:08 PM 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. Michelle Logan on behalf of Courtney Bowline Bar No. 24055206 mlogan@brianlauten.com Envelope ID: 87571335 Filing Code Description: Non-Signed Proposed Order/Judgment Filing Description: PROPOSED ORDER FOR SHOW CAUSE Status as of 5/9/2024 2:42 PM CST Case Contacts Stephanie Rzepka stephanie.rzepka@tuckerellis.com 5/9/2024 2:19:08 PM SENT Sarah Prince sarah.prince@crowedunlevy.com 5/9/2024 2:19:08 PM SENT Joshua Fellenbaum joshua.fellenbaum@tuckerellis.com 5/9/2024 2:19:08 PM SENT Elizabeth Palmer empalmer9009@gmail.com 5/9/2024 2:19:08 PM SENT Associated Case Party: GLOBAL OIL & GAS FIELDS OKLAHOMA LLC Name BarNumber Email TimestampSubmitted Status Chad M.Eggspuehler Chad.Eggspuehler@tuckerellis.com 5/9/2024 2:19:08 PM SENT Associated Case Party: WILLIAM J. STAVOLE Name BarNumber Email Timestam pSubmitted Status William Stavole william.stavole@tuckerellis.com 5/9/2024 2:19:08 PM SENT