Preview
FILED
DALLAS COUNTY
8/15/2019 4:23 PM
FELICIA PITRE
DISTRICT CLERK
Rosa Delacerda
CAUSE N0. DC-l9—10734
JEANNIE WOOLSLAYER § IN THE DISTRICT COURT
§
Plaintifif §
§
v. §
§
LEE C. MOORE, INC., A/K/A §
WOOSLAYER COMPANIES, INC., §
RANDY WOLF, IN HIS CAPACITES AS §
VOTING TRUSTEE FOR THE ROBERT T. §
WOOLSLAYER GST TRUST, VOTING §
TRUSTEE FOR THE HOMER § 298TH JUDICIAL DISTRICT OF
WOOLSLAYER GST TRUST, VOTING §
TRUSTEE FOR THE JOHN WOOSLAYER §
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 0F §
THE WOOLSLAYER GST TRUSTS, §
§
Defendants. § DALLAS COUNTY, TEXAS
UNOPPOSED MOTION FOR ADMISSION PRO HAC VICE
To the Honorable Judge of Said CouIt:
Pursuant to Rule XIX of the Rules Governing Admission to the Bar of Texas and
§82.0361 of Texas Government Code, the undersigned non-rcsident attorney, James C. Milton
(“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:
James C. Milton, Esq.
Oklahoma State Bar No. 16697
MOTION FOR ADMISSION PRO HAC VICE — Page 1
Hall, Estill, Hardwick, Gable, Golden & Nelson, P.C.
320 South Boston Avenue, Suite 200
Tulsa, OK 74103-3706
918-594-0400
918-594-0505 (fax)
jmilton@hallestill.com
2. Name and State Bar number of an attorney licensed in Texas with whom the non-residcnt
attorney will be associated in the Texas proceedings and that attomey’s ofiice address, telephone
number and telecopier number:
Matthew K. Good
Texas BarNo‘. a #09 a 3 (q
Conner & Winters LLP
1700 Pacific Avenue, Ste. 2250
Dallas, Texas 75201
214-217-8040
214-217-8861 fax
mgood@cw1aw.com
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:
In the Matter of the Estate ofBilly Gene Burks, Deceased, Cause No. PR14736, In the
County Court of Hill County, Texas.
4. List of alljurisdictions in which the non-residcnt 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:
The Supreme Court of Oklahoma for practice in all Oklahoma state courts; the U.S.
Supreme Court; the U.S. Court of Appeals for the Tenth Circuit; and the U.S. District Courts for
MOTION FOR ADMISSION PRO HAC VICE — Page 2
the Northem, Eastern, and Western Districts of Oklahoma. I am an active mémbér in good
standing in each of 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:
I have not been the subject of disciplinary action by the Bar or courts of any jurisdiction
in which I am licensed within the preceding five (5) years or at any time.
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:
I have not been denied admission to the courts of any State or to any federal court during
the preceding five (5) years or at any time.
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 ag.
this proceeding ispending or I have withdrawn as counsel herein.
MOTION FOR ADMISSION PRO HAC VICE — Page 3
B. Compliance with §82.036l of Texas Government Code
Movant would show that, having applied 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]
MOTION FOR ADMISSION PRO HAC VICE — Page 4
Wherefore, Premises Considered, Movant, James C. Milton, 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 ovant y be justly entitled.
Dated: 8g I 51 [q
Respectfully submitted,
/
1/4.? ‘\
James c. Milton, E -q.
“WP a
Oklahoma
K a .
11am, Estin,
State 13‘ No.
Hardwick, Gable,
16697
"
Golden gNel’éon, P.C.
320 South Boston Avenue, Suite 200
Tulsa, 0K 74103-3706
918-594-0400
918-594-0505 (fax)
jmilton@fi11estill.oom
VERIFICATION
Aer
I, James C. Milton, have read the foregoing statements, and I swear and depose that they
are of my knowledge and are true and correct.
James C. Milton
MOTION FOR ADMISSION PRO HAC VICE— Page 5
STATE OF OKLAHOMA
COUNTY OF TULSA
BEFORE ME, the undersigned authority, appeared James C. Milton, 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 Commission Expires:
fl
‘92 5 ’QQ '9
Q N016 Public
8 N M
SlatoogfwOpklahcom
JOANNE LEE SPRING
.‘o
KMLU GEE c N
CERTIFICATE OF CONFERENCE ‘52” coumssnou ”$123,
Comm. Exp 08--25 2019
The Undersigned certifies that he has discussed the above Motion with counsel for
Plaintiff and this Motion'ls unopposed.
Matthew K. Good
CERTIFICATE OF SERVICE
of the foregoing document was served via e-
sggfitify that a true and
I herebyc correct copy
mail on the {5 day of August 2019, upon counsel for Plaintiff, as follows:
Larry A. Flournoy, Jr.
Chad T. McLain
Abbey Cohen
10000 N. Central Expy.
Suite 800
Dallas, Texas 75231
7""
HUM?
Matthew K. Good
gkm/
“66795.1 :005352:00001
MOTION FOR ADMISSION PRO HAC VICE — Page 6
Board of Law Examiners
Appointed by the Supreme Court of Texas
August 12, 2019
James C. Milton
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 isrequesting
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: James C. Milton
Case: DC—l9—10734
Texas court or body: District Court, 298th Judicial District, Dallas County, Texas
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 isrequesting 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 thisAcknowledgment 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 ismade by the Texas court or body in which itis filed.
For more infomation, 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.
Signed,
,gzéwflwfi
Susan Henricks
Executiw Director
MAILING ADDRESS TELEPHONE: 512- 463-1621
-FACSIMILE: 512- 463-5300 STREET ADDRESS
Post Office Box 13486 WEBSITE: www.ble.texas.gov 205 West 14th Ste.500
Street,
Austin,Texas 7871 1-3486 Austin, Texas 78701
Exhibit “A”
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FILED DALLAS COUNTY 8/15/2019 4:23 PM FELICIA PITRE DISTRICT CLERK Rosa Delacerda CAUSE N0. DC-l9—10734 JEANNIE WOOLSLAYER § IN THE DISTRICT COURT § Plaintifif § § v. § § LEE C. MOORE, INC., A/K/A § WOOSLAYER COMPANIES, INC., § RANDY WOLF, IN HIS CAPACITES AS § VOTING TRUSTEE FOR THE ROBERT T. § WOOLSLAYER GST TRUST, VOTING § TRUSTEE FOR THE HOMER § 298TH JUDICIAL DISTRICT OF WOOLSLAYER GST TRUST, VOTING § TRUSTEE FOR THE JOHN WOOSLAYER § 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 0F § THE WOOLSLAYER GST TRUSTS, § § Defendants. § DALLAS COUNTY, TEXAS UNOPPOSED MOTION FOR ADMISSION PRO HAC VICE To the Honorable Judge of Said CouIt: Pursuant to Rule XIX of the Rules Governing Admission to the Bar of Texas and §82.0361 of Texas Government Code, the undersigned non-rcsident attorney, James C. Milton (“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: James C. Milton, Esq. Oklahoma State Bar No. 16697 MOTION FOR ADMISSION PRO HAC VICE — Page 1 Hall, Estill, Hardwick, Gable, Golden & Nelson, P.C. 320 South Boston Avenue, Suite 200 Tulsa, OK 74103-3706 918-594-0400 918-594-0505 (fax) jmilton@hallestill.com 2. Name and State Bar number of an attorney licensed in Texas with whom the non-residcnt attorney will be associated in the Texas proceedings and that attomey’s ofiice address, telephone number and telecopier number: Matthew K. Good Texas BarNo‘. a #09 a 3 (q Conner & Winters LLP 1700 Pacific Avenue, Ste. 2250 Dallas, Texas 75201 214-217-8040 214-217-8861 fax mgood@cw1aw.com 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: In the Matter of the Estate ofBilly Gene Burks, Deceased, Cause No. PR14736, In the County Court of Hill County, Texas. 4. List of alljurisdictions in which the non-residcnt 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: The Supreme Court of Oklahoma for practice in all Oklahoma state courts; the U.S. Supreme Court; the U.S. Court of Appeals for the Tenth Circuit; and the U.S. District Courts for MOTION FOR ADMISSION PRO HAC VICE — Page 2 the Northem, Eastern, and Western Districts of Oklahoma. I am an active mémbér in good standing in each of 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: I have not been the subject of disciplinary action by the Bar or courts of any jurisdiction in which I am licensed within the preceding five (5) years or at any time. 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: I have not been denied admission to the courts of any State or to any federal court during the preceding five (5) years or at any time. 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 ag. this proceeding ispending or I have withdrawn as counsel herein. MOTION FOR ADMISSION PRO HAC VICE — Page 3 B. Compliance with §82.036l of Texas Government Code Movant would show that, having applied 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] MOTION FOR ADMISSION PRO HAC VICE — Page 4 Wherefore, Premises Considered, Movant, James C. Milton, 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 ovant y be justly entitled. Dated: 8g I 51 [q Respectfully submitted, / 1/4.? ‘\ James c. Milton, E -q. “WP a Oklahoma K a . 11am, Estin, State 13‘ No. Hardwick, Gable, 16697 " Golden gNel’éon, P.C. 320 South Boston Avenue, Suite 200 Tulsa, 0K 74103-3706 918-594-0400 918-594-0505 (fax) jmilton@fi11estill.oom VERIFICATION Aer I, James C. Milton, have read the foregoing statements, and I swear and depose that they are of my knowledge and are true and correct. James C. Milton MOTION FOR ADMISSION PRO HAC VICE— Page 5 STATE OF OKLAHOMA COUNTY OF TULSA BEFORE ME, the undersigned authority, appeared James C. Milton, 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 Commission Expires: fl ‘92 5 ’QQ '9 Q N016 Public 8 N M SlatoogfwOpklahcom JOANNE LEE SPRING .‘o KMLU GEE c N CERTIFICATE OF CONFERENCE ‘52” coumssnou ”$123, Comm. Exp 08--25 2019 The Undersigned certifies that he has discussed the above Motion with counsel for Plaintiff and this Motion'ls unopposed. Matthew K. Good CERTIFICATE OF SERVICE of the foregoing document was served via e- sggfitify that a true and I herebyc correct copy mail on the {5 day of August 2019, upon counsel for Plaintiff, as follows: Larry A. Flournoy, Jr. Chad T. McLain Abbey Cohen 10000 N. Central Expy. Suite 800 Dallas, Texas 75231 7"" HUM? Matthew K. Good gkm/ “66795.1 :005352:00001 MOTION FOR ADMISSION PRO HAC VICE — Page 6 Board of Law Examiners Appointed by the Supreme Court of Texas August 12, 2019 James C. Milton 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 isrequesting 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: James C. Milton Case: DC—l9—10734 Texas court or body: District Court, 298th Judicial District, Dallas County, Texas 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 isrequesting 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 thisAcknowledgment 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 ismade by the Texas court or body in which itis filed. For more infomation, 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. Signed, ,gzéwflwfi Susan Henricks Executiw Director MAILING ADDRESS TELEPHONE: 512- 463-1621 -FACSIMILE: 512- 463-5300 STREET ADDRESS Post Office Box 13486 WEBSITE: www.ble.texas.gov 205 West 14th Ste.500 Street, Austin,Texas 7871 1-3486 Austin, Texas 78701 Exhibit “A”