Preview
Filed: 5/7/2019 4:43 PM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 33382392
By: Shailja Dixit
5/7/2019 4:51 PM
Cause No. 17-CV-1242
BLANCHARD REFINING COMPANY § IN THE DISTRICT COURT OF
LLC and MARATHON PETROLEUM §
COMPANY LP §
§
§ GALVESTON COUNTY, TEXAS
v. §
§
§
INDUSTRIAL SPECIALISTS, LLC § 212th DISTRICT COURT
MARK D. LATHAM’S UNOPPOSED MOTION FOR ADMISSION PRO HAC VICE
TO THE HONORABLE COURT:
I, Mark D. Latham, file this Motion for Admission Pro Hac Vice to appear before the Court,
under the authority of the Rules Governing Admission to the Bar of Texas, Rule XIX.
BACKGROUND
1. I am associated with Michael A. Golemi, who will personally participate in the hearings
and trial of this case. Michael A. Golemi is a practicing attorney and member of the State Bar of
Texas. His information is as follows:
Texas Bar No: 24047536
Address: 1001 Fannin, Suite 1800
Houston, Texas 77002
Telephone: 713-651-2900
Fax Number: 713-651-2908
E-mail: magolemi@liskow.com
2. I am an active member in good standing with the State Bar of Louisiana, I am admitted to
practice in all state courts in Louisiana, the United States Court of Appeals for the Fifth Circuit,
the United States District Court for the Eastern District of Louisiana, the United States District
Court for the Middle District of Louisiana, and the United States District Court for the Western
District of Louisiana.
3. I have not been the subject of disciplinary action in the last five years by the bar or courts
of any jurisdiction where I have been licensed.
4. I have not been denied admission to any state or federal court during the last five years.
5. I am 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. I will at all
times abide by and comply with these rules as long as this case is pending and I have not withdrawn
as counsel from the proceeding.
6. The cases in which I have appeared or sought leave to appear in Texas courts in the last
two years are as follows:
Caption: Court: Cause No.
C.E., Y.T., Individually and on 56th Judicial District Court of 16-MDL-0001 (CV-0075674)
behalf of C.E., E.S. et al. v. Galveston County, Texas
Marathon Petroleum
Company LP et al.,
7. My office address, telephone number, fax number and e-mail address are included below
my signature.
8. The Non-Resident Attorney fee has been paid to the Board of Law Examiners of Texas
and the Acknowledgement Letter is attached hereto as Exhibit 1.
PRAYER
9. For these reasons, I ask this Court to grant my Motion for Admission Pro Hac Vice and
allow me to appear before this Court until the conclusion of this case.
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Respectfully submitted,
LISKOW & LEWIS
/s/ Mark D. Latham
Mark D. Latham
Louisiana Bar No. 19673
One Shell Square
701 Poydras Street, Suite 5000
New Orleans, La. 70139
Telephone: (504) 581-7979
Facsimile: (504) 556-4120
E-mail: mdlatham@liskow.com
CERTIFICATE OF CONFERENCE
I hereby certify that I conferred via email on May 7, 2019 with Joel Z. Montgomery,
counsel for Plaintiffs Blanchard Refining Company LLC and Marathon Petroleum Company LP,
regarding Mark D. Latham’s Motion for Admission Pro Hac Vice and Plaintiffs indicated that they
do not oppose the motion.
/s/ James T. Kittrell
James T. Kittrell
-3-
CERTIFICATE OF SERVICE
I hereby certify that a copy of Mark D. Latham’s Motion for Admission Pro Hac Vice is
being served on all counsel of record on May 7, 2019, by the method indicated below.
/s/ Michael A. Golemi
Michael A. Golemi
Joel Z. Montgomery Certified Mail – RRR
Jonathan B. Smith
Z. Alex Ramirez No.:
SHIPLEY SNELL MONTGOMERY
712 Main Street, Suite 1400 Private Delivery
Houston, Texas 77002
Telephone: (713) 652-5920 E-Mail
Facsimile: (713) 652-3057
Email: jmontgomery@shipleysnell.com Personal Delivery
Email: jsmith@shipleysnell.com
Email: arodriguez@shipleysnell.com
Attorneys for Plaintiff Blanchard Refining
Company, LLC
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Board of Law Examiners
Appointed by the Supreme Court of Texas
May 07, 2019
Mark D. Latham
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: Mark D. Latham
Case: 17-cv-1242
Texas court or body: 212th District Court - Galveston County, TX
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
EXHIBIT 1
Cause No. 17-CV-1242
BLANCHARD REFINING COMPANY § IN THE DISTRICT COURT OF
LLC and MARATHON PETROLEUM §
COMPANY LP §
§
§ GALVESTON COUNTY, TEXAS
v. §
§
§
INDUSTRIAL SPECIALISTS, LLC § 212th DISTRICT COURT
MICHAEL A. GOLEMI’S MOTION IN SUPPORT OF MARK D.
LATHAM’S MOTION FOR ADMISSION PRO HAC VICE
TO THE HONORABLE COURT:
I, Michael A. Golemi, file this motion in support of Mark D. Latham’s Motion for
Admission Pro Hac Vice to appear before the Court.
BACKGROUND
1. I am associated with Mark D. Latham on this case. I am employed as an attorney
on this case and will personally participate in the hearings and trial.
2. I am a practicing attorney and a member in good standing with the State Bar of
Texas. My State Bar number, office address, telephone number, fax number, and e-mail address
are included below my signature.
3. Mark D. Latham is a reputable attorney in his state, and I recommend that the Court
permit him to appear in this case.
CONCLUSION
4. For these reasons, I ask this Court to grant Mark D. Latham’s Motion for Admission
Pro Hac Vice and allow him to appear before the Court in this case.
Respectfully submitted,
LISKOW & LEWIS
/s/ Michael A. Golemi
Michael A. Golemi
State Bar No. 24047536
1001 Fannin, Suite 1800
Houston, Texas 77002
Telephone: (713) 651-2900
Facsimile: (713) 651-2908
Email: magolemi@liskow.com
ATTORNEY FOR DEFENDANT
INDUSTRIAL SPECIALISTS, LLC
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CERTIFICATE OF SERVICE
I hereby certify that a copy of Michael A. Golemi’s Motion in Support of Mark D. Latham’s
Motion for Admission Pro Hac Vice is being served on all counsel of record on May 7, 2019, by
the method indicated below.
/s/ Michael A. Golemi
Michael A. Golemi
Joel Z. Montgomery Certified Mail – RRR
Jonathan B. Smith
Z. Alex Ramirez No.:
SHIPLEY SNELL MONTGOMERY
712 Main Street, Suite 1400 Private Delivery
Houston, Texas 77002
Telephone: (713) 652-5920 E-Mail
Facsimile: (713) 652-3057
Email: jmontgomery@shipleysnell.com Personal Delivery
Email: jsmith@shipleysnell.com
Email: arodriguez@shipleysnell.com
Attorneys for Plaintiff Blanchard Refining
Company, LLC
-3-
Preview
Filed: 5/7/2019 4:43 PM JOHN D. KINARD - District Clerk Galveston County, Texas Envelope No. 33382392 By: Shailja Dixit 5/7/2019 4:51 PM Cause No. 17-CV-1242 BLANCHARD REFINING COMPANY § IN THE DISTRICT COURT OF LLC and MARATHON PETROLEUM § COMPANY LP § § § GALVESTON COUNTY, TEXAS v. § § § INDUSTRIAL SPECIALISTS, LLC § 212th DISTRICT COURT MARK D. LATHAM’S UNOPPOSED MOTION FOR ADMISSION PRO HAC VICE TO THE HONORABLE COURT: I, Mark D. Latham, file this Motion for Admission Pro Hac Vice to appear before the Court, under the authority of the Rules Governing Admission to the Bar of Texas, Rule XIX. BACKGROUND 1. I am associated with Michael A. Golemi, who will personally participate in the hearings and trial of this case. Michael A. Golemi is a practicing attorney and member of the State Bar of Texas. His information is as follows: Texas Bar No: 24047536 Address: 1001 Fannin, Suite 1800 Houston, Texas 77002 Telephone: 713-651-2900 Fax Number: 713-651-2908 E-mail: magolemi@liskow.com 2. I am an active member in good standing with the State Bar of Louisiana, I am admitted to practice in all state courts in Louisiana, the United States Court of Appeals for the Fifth Circuit, the United States District Court for the Eastern District of Louisiana, the United States District Court for the Middle District of Louisiana, and the United States District Court for the Western District of Louisiana. 3. I have not been the subject of disciplinary action in the last five years by the bar or courts of any jurisdiction where I have been licensed. 4. I have not been denied admission to any state or federal court during the last five years. 5. I am 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. I will at all times abide by and comply with these rules as long as this case is pending and I have not withdrawn as counsel from the proceeding. 6. The cases in which I have appeared or sought leave to appear in Texas courts in the last two years are as follows: Caption: Court: Cause No. C.E., Y.T., Individually and on 56th Judicial District Court of 16-MDL-0001 (CV-0075674) behalf of C.E., E.S. et al. v. Galveston County, Texas Marathon Petroleum Company LP et al., 7. My office address, telephone number, fax number and e-mail address are included below my signature. 8. The Non-Resident Attorney fee has been paid to the Board of Law Examiners of Texas and the Acknowledgement Letter is attached hereto as Exhibit 1. PRAYER 9. For these reasons, I ask this Court to grant my Motion for Admission Pro Hac Vice and allow me to appear before this Court until the conclusion of this case. -2- Respectfully submitted, LISKOW & LEWIS /s/ Mark D. Latham Mark D. Latham Louisiana Bar No. 19673 One Shell Square 701 Poydras Street, Suite 5000 New Orleans, La. 70139 Telephone: (504) 581-7979 Facsimile: (504) 556-4120 E-mail: mdlatham@liskow.com CERTIFICATE OF CONFERENCE I hereby certify that I conferred via email on May 7, 2019 with Joel Z. Montgomery, counsel for Plaintiffs Blanchard Refining Company LLC and Marathon Petroleum Company LP, regarding Mark D. Latham’s Motion for Admission Pro Hac Vice and Plaintiffs indicated that they do not oppose the motion. /s/ James T. Kittrell James T. Kittrell -3- CERTIFICATE OF SERVICE I hereby certify that a copy of Mark D. Latham’s Motion for Admission Pro Hac Vice is being served on all counsel of record on May 7, 2019, by the method indicated below. /s/ Michael A. Golemi Michael A. Golemi Joel Z. Montgomery Certified Mail – RRR Jonathan B. Smith Z. Alex Ramirez No.: SHIPLEY SNELL MONTGOMERY 712 Main Street, Suite 1400 Private Delivery Houston, Texas 77002 Telephone: (713) 652-5920 E-Mail Facsimile: (713) 652-3057 Email: jmontgomery@shipleysnell.com Personal Delivery Email: jsmith@shipleysnell.com Email: arodriguez@shipleysnell.com Attorneys for Plaintiff Blanchard Refining Company, LLC -4- Board of Law Examiners Appointed by the Supreme Court of Texas May 07, 2019 Mark D. Latham 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: Mark D. Latham Case: 17-cv-1242 Texas court or body: 212th District Court - Galveston County, TX 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 EXHIBIT 1 Cause No. 17-CV-1242 BLANCHARD REFINING COMPANY § IN THE DISTRICT COURT OF LLC and MARATHON PETROLEUM § COMPANY LP § § § GALVESTON COUNTY, TEXAS v. § § § INDUSTRIAL SPECIALISTS, LLC § 212th DISTRICT COURT MICHAEL A. GOLEMI’S MOTION IN SUPPORT OF MARK D. LATHAM’S MOTION FOR ADMISSION PRO HAC VICE TO THE HONORABLE COURT: I, Michael A. Golemi, file this motion in support of Mark D. Latham’s Motion for Admission Pro Hac Vice to appear before the Court. BACKGROUND 1. I am associated with Mark D. Latham on this case. I am employed as an attorney on this case and will personally participate in the hearings and trial. 2. I am a practicing attorney and a member in good standing with the State Bar of Texas. My State Bar number, office address, telephone number, fax number, and e-mail address are included below my signature. 3. Mark D. Latham is a reputable attorney in his state, and I recommend that the Court permit him to appear in this case. CONCLUSION 4. For these reasons, I ask this Court to grant Mark D. Latham’s Motion for Admission Pro Hac Vice and allow him to appear before the Court in this case. Respectfully submitted, LISKOW & LEWIS /s/ Michael A. Golemi Michael A. Golemi State Bar No. 24047536 1001 Fannin, Suite 1800 Houston, Texas 77002 Telephone: (713) 651-2900 Facsimile: (713) 651-2908 Email: magolemi@liskow.com ATTORNEY FOR DEFENDANT INDUSTRIAL SPECIALISTS, LLC -2- CERTIFICATE OF SERVICE I hereby certify that a copy of Michael A. Golemi’s Motion in Support of Mark D. Latham’s Motion for Admission Pro Hac Vice is being served on all counsel of record on May 7, 2019, by the method indicated below. /s/ Michael A. Golemi Michael A. Golemi Joel Z. Montgomery Certified Mail – RRR Jonathan B. Smith Z. Alex Ramirez No.: SHIPLEY SNELL MONTGOMERY 712 Main Street, Suite 1400 Private Delivery Houston, Texas 77002 Telephone: (713) 652-5920 E-Mail Facsimile: (713) 652-3057 Email: jmontgomery@shipleysnell.com Personal Delivery Email: jsmith@shipleysnell.com Email: arodriguez@shipleysnell.com Attorneys for Plaintiff Blanchard Refining Company, LLC -3-