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CAUSE NO. 2017-48075
TOTAL PETROCHEMICALS & INTHE DISTRICT COURT
REFININGUSA, INC., and.
ACE PROPERTY & CASUALTY
INSURANCE COMPANY,
HARRIS COUNTY
KINDER MORGAN PETCOKE, LP
AND KINDER MORGAN PETCOKE
GP LLC 164th DISTRICT COURT
DANNY L. WORKER’S MOTION
FOR ADMISSION PRO HAC VICE
Danny L. Workermoves
the court for pro hac vice admission
to appear
in this matter and, in
support, states as follows:
I am legal counsel for Ace Property & Casualty Insurance Company, and seek
pemnission to appear pro hac vice before the Court, under the authority of the Rules Goveming
Admission to the Bar of Texas, Rule 19, Texas Govemment Code §82.001 et seq.
I am associated
with Sarah R. Smith, also counsel for Ace Property
& Casualty
Insurance Company, who will personally participate in the hearings and trial of this case. Sarah R.
Smith is a practicing attomey and member of the State Bar of Texas, Bar No. 24056346. Sarah R.
Smith’s firm, office address, telephone number, fax number
and email address
are as follows:
Lewis Brisbois Bisgaard & Smith LLC
24 Greenway Plaza, Suite 1400
Houston, Texas 77046
(713) 659-6767 - Phone
(713) 759-6830 - Fax
sarah.smith@lewisbrisbois.com
I am an active member in good standing with the State Bar of Illinois, Bar No.
4851-1795-7786.1
4. Ihave not been the subject of any disciplinary action in the last five years by the bar
of courts of any jurisdiction
where I have been licensed
or admitted pro hac vice and have not been
denied admission to any state or federal court during the last five years.
5, Tam familiar
with the State Bar Acct, the State Bar Rules, and the Texas Disciplinary
Rules of Professional Conduct goveming
the conduct of members of the State of Texas. I will, atall
times, abide by and comply with these rules as longas this case is pending and I have not withdrawn
as counsel from these proceedings.
6. I have paid the non-resident attomey fee as required by Texas Govemment Code
§82.001. A copy of the Board of Law Examiners Acknowledgment Letteris attached to this motion
as Exhibit
A.
7, I have appeared pro hac vice in the following case(s) in Texas courts in the last two
years: None.
8. My office address, telephone number, and fax number are included below.
For these reasons, I ask the Court to grant my Motion for Admission Pro Hac Vice and
allow me to appear before this Court until the conclusion of this case.
Respectfully submitted,
LEWIS BRISBOIS BISGAARD & SMITH LLP
/s/ Danny L. Worker
Danny L. Worker
Illinois Bar No: 6195554
550 W Adams Street #800
Chicago, IL 60661
Tel: 312.345.1718
Fax: 312.345.1778
Dan.Worker@lewisbrisbois.com
ATTORNEY FOR PLAINTIFF, ACE
PROPERTY & CASUALTY INSURANCE
COMPANY
4851-1795-7786.1 2
CERTIFICATE OF SERVICE
I ify that a true and correct copy of the foregoing Instrument has been served on.
all known counsel of record by electronic filing and/or facsimile on this the 19" day of June, 2019.
James M. Bettis Via E-Service
Paul D. Scull
Munsch Hardt Kofp & Harr, P.C.
700 Milam St., Suite 2700
Houston, Texas 77002-2806
Attomeys
for Kinder Morgan.
Petcoke,
LP and Kinder Morgan.
Petooke, LLC
Jack G. Camegie Via E-Serve
Clark Hill Strasburker
909 Fannin, Suite 2300
Houston, Texas 77010
Attomeys for Total Petrochemicals
& Refining USA, Inc.
/s/ Sarah Sith
Sarah R. Smith
4851-1795-7786.1
VERIFICATION
STATE OF ILLINOIS §
§
COUNTY OF §
Before me, the undersigned Notary Public, on this day personally appeared Danny L.
Worker, and after being duly sworn under oath that he is competent and authorized to make this
verification; that he has read this Motion for Admission Pro Hac Vice; and that each statement made
and contained therein are within his personal knowledge and are true and correct.
Hon bk
Danny L. Worker
SUBSCRIBED AND SWORN TO BEFORE ME on this { ah day of June, 2019, to certify
which witness my hand and seal of office.
of Illinois
OFFICIAL SEAL
AMANDA D WALSH
NOTARY PUBLIC - STATE OF ILLINOIS
MY COMMISSION EXPIRES:02/05/20
ARIALLILY
4817-5733-6986.1
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CAUSE NO. 2017-48075 TOTAL PETROCHEMICALS & INTHE DISTRICT COURT REFININGUSA, INC., and. ACE PROPERTY & CASUALTY INSURANCE COMPANY, HARRIS COUNTY KINDER MORGAN PETCOKE, LP AND KINDER MORGAN PETCOKE GP LLC 164th DISTRICT COURT DANNY L. WORKER’S MOTION FOR ADMISSION PRO HAC VICE Danny L. Workermoves the court for pro hac vice admission to appear in this matter and, in support, states as follows: I am legal counsel for Ace Property & Casualty Insurance Company, and seek pemnission to appear pro hac vice before the Court, under the authority of the Rules Goveming Admission to the Bar of Texas, Rule 19, Texas Govemment Code §82.001 et seq. I am associated with Sarah R. Smith, also counsel for Ace Property & Casualty Insurance Company, who will personally participate in the hearings and trial of this case. Sarah R. Smith is a practicing attomey and member of the State Bar of Texas, Bar No. 24056346. Sarah R. Smith’s firm, office address, telephone number, fax number and email address are as follows: Lewis Brisbois Bisgaard & Smith LLC 24 Greenway Plaza, Suite 1400 Houston, Texas 77046 (713) 659-6767 - Phone (713) 759-6830 - Fax sarah.smith@lewisbrisbois.com I am an active member in good standing with the State Bar of Illinois, Bar No. 4851-1795-7786.1 4. Ihave not been the subject of any disciplinary action in the last five years by the bar of courts of any jurisdiction where I have been licensed or admitted pro hac vice and have not been denied admission to any state or federal court during the last five years. 5, Tam familiar with the State Bar Acct, the State Bar Rules, and the Texas Disciplinary Rules of Professional Conduct goveming the conduct of members of the State of Texas. I will, atall times, abide by and comply with these rules as longas this case is pending and I have not withdrawn as counsel from these proceedings. 6. I have paid the non-resident attomey fee as required by Texas Govemment Code §82.001. A copy of the Board of Law Examiners Acknowledgment Letteris attached to this motion as Exhibit A. 7, I have appeared pro hac vice in the following case(s) in Texas courts in the last two years: None. 8. My office address, telephone number, and fax number are included below. For these reasons, I ask the Court to grant my Motion for Admission Pro Hac Vice and allow me to appear before this Court until the conclusion of this case. Respectfully submitted, LEWIS BRISBOIS BISGAARD & SMITH LLP /s/ Danny L. Worker Danny L. Worker Illinois Bar No: 6195554 550 W Adams Street #800 Chicago, IL 60661 Tel: 312.345.1718 Fax: 312.345.1778 Dan.Worker@lewisbrisbois.com ATTORNEY FOR PLAINTIFF, ACE PROPERTY & CASUALTY INSURANCE COMPANY 4851-1795-7786.1 2 CERTIFICATE OF SERVICE I ify that a true and correct copy of the foregoing Instrument has been served on. all known counsel of record by electronic filing and/or facsimile on this the 19" day of June, 2019. James M. Bettis Via E-Service Paul D. Scull Munsch Hardt Kofp & Harr, P.C. 700 Milam St., Suite 2700 Houston, Texas 77002-2806 Attomeys for Kinder Morgan. Petcoke, LP and Kinder Morgan. Petooke, LLC Jack G. Camegie Via E-Serve Clark Hill Strasburker 909 Fannin, Suite 2300 Houston, Texas 77010 Attomeys for Total Petrochemicals & Refining USA, Inc. /s/ Sarah Sith Sarah R. Smith 4851-1795-7786.1 VERIFICATION STATE OF ILLINOIS § § COUNTY OF § Before me, the undersigned Notary Public, on this day personally appeared Danny L. Worker, and after being duly sworn under oath that he is competent and authorized to make this verification; that he has read this Motion for Admission Pro Hac Vice; and that each statement made and contained therein are within his personal knowledge and are true and correct. Hon bk Danny L. Worker SUBSCRIBED AND SWORN TO BEFORE ME on this { ah day of June, 2019, to certify which witness my hand and seal of office. of Illinois OFFICIAL SEAL AMANDA D WALSH NOTARY PUBLIC - STATE OF ILLINOIS MY COMMISSION EXPIRES:02/05/20 ARIALLILY 4817-5733-6986.1