# Ensign Services, L.L.C. (f/K/A Fe Services, L.L.C.), Fe Services Holdings Inc., and James Stewart v. Marc Jan Levesconte > Texas Court of Appeals, 1st District (Houston) ยท June 9, 2015 URL: https://www.frixlaw.com/law-library/cases/4056623 ## Case - **Court:** Texas Court of Appeals, 1st District (Houston) - **Decided:** June 9, 2015 - **Precedential status:** Published - **Opinion:** Opinion - **Cited by:** 0 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4056623 ## Opinion text ACCEPTED 01-14-01026-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 6/9/2015 4:33:59 PM CHRISTOPHER PRINE CLERK No. 01-14-01026-CV IN THE COURT OF APPEALS OF TEXAS FILED IN 1st COURT OF APPEALS FOR THE FIRST DISTRICT HOUSTON, TEXAS HOUSTON, TEXAS 6/9/2015 4:33:59 PM CHRISTOPHER A. PRINE Clerk ENSIGN SERVICES, LLC (F/K/A FE SERVICES, L.L.C.), FE SERVICES HOLDINGS, INC., AND JAMES STEWART, Appellants, V. MARC JAN LEVESCONTE Appellee. Appealed from the 333rd District Court of Harris County, Texas, Cause No. 2009-04966 UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF JAMES M. HARRIS TO THE HONORABLE COURT OF APPEALS OF TEXAS FOR THE FIRST DISTRICT OF HOUSTON, TEXAS: Appellants Ensign Services, L.L.C. (f/k/a FE Services, L.L.C.), FE Services Holdings, Inc., and James Stewart ("Appellants") respectfully file their Unopposed Motion for Pro Hac Vice Admission of James M. Harris pursuant to Texas Government Code Section 82.001, et seq. and Rule XIX of the Rules Governing Admission to the Bar of Texas. The undersigned counsel has consulted with Mr. Kelley, the attorney representing Appellee Marc Jan Levesconte ("Appellee"). Mr. Kelley states that Appellee does not oppose this motion. 1. Mr. Harris's contact information is: Seyfarth Shaw, LLP, 2029 Century Park East 3500, Los Angeles, California 90067; Phone: (310) 277-7200; Fax: (310) 201-5219; email: jmharris@seyfarth.com. 2. Emma C. Mata is an attorney licensed in Texas and will remain associated in these proceedings. Ms. Mata's contact information is: Seyfarth Shaw LLP, 700 Milam Street, Suite 1400, Houston, Texas 77002; Phone: (713) 225-2300; Facsimile: (713) 225-2340; email: emata@seyfarth.com, Texas State Bar No. 24029470. 3. Mr. Harris has not appeared or sought leave to appear in any Texas federal or state courts within the past two years. 4. Mr. Harris is an active member in good standing in each of the following courts and jurisdictions: a. State of California; b. District of Columbia; c. United States Court of Appeals, for the Second, Fourth, Fifth, Sixth, Ninth, and Tenth Circuits; and d. United States Supreme Court. 5. Mr. Harris has not been the subject of any disciplinary action by the State of California Bar, District of Columbia Bar, or any state or federal courts in any jurisdiction of the United States. 6. Mr. Harris has not been denied admission to any state or federal courts in the United States during the preceding five (5) years. 7. Mr. Harris is familiar with the Texas State Bar Act, the Texas 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 same so long as this matter is pending and he has not withdrawn as counsel herein. 8. Pursuant to Rule XIX(b) of the Rules Governing Admission to the Bar of Texas, Appellants submit Ms. Mata's motion, which contains a statement that she finds Mr. Harris to be a reputable attorney and recommending that Mr. Harris be granted permission to participate in this matter before this Court. See Exhibit A, E. Mata's Rule XIX(b) Motion. 9. Pursuant to Rule XIX(c) of the Rules Governing Admission to the Bar of Texas, Appellants submit the Non-Resident Acknowledgement Letter from the Texas State Board of Law Examiners. See Exhibit B, Acknowledgement Letter. WHEREFORE, Appellants respectfully request that this Motion be granted and grant such other and further relief as is just and appropriate under the circumstances. Respectfully submitted, /s/ Robert J Carty, Jr. Emma C. Mata Texas Bar No. 24029470 emata@seyfarth.corn Robert J. Carty, Jr. Texas Bar No. 00788794 rcarty@seyfarth. corn Seyfarth Shaw LLP 700 Milam St., Suite 1400 Houston, Texas 77002 Telephone: (713) 225-2300 Facsimile : (713) 225-2340 Wanda McKee Fowler Texas Bar No. 13698700 fowler@wrightclose.com Wright & Close LLP Three Riverway, Suite 600 Houston, Texas 77056 Telephone: (713) 572-4321 Facsimile: (713) 572-4320 ATTORNEYS FOR APPELLANTS ENSIGN SERVICES, L.L.C. (F/K/A FE SERVICES, L.L.C.), FE SERVICES HOLDINGS, INC., AND JAMES STEWART CERTIFICATE OF CONFERENCE I certify that, on June 5, 2015, I conferred with Appellee's counsel, Lloyd Kelley; and that Mr. Kelley informed me that Appellee does not oppose this Motion. /s/ Emma C Mata Emma C. Mata CERTIFICATE OF SERVICE I hereby certify that on this 9th day of June, 2015, a true and correct copy of the foregoing instrument was properly forwarded to counsel of record for Marc Jan LeVesconte, Cross-Appellant/Appellee in accordance with the Texas Rules of Appellate Procedure, as follows: Lloyd E. Kelley THE KELLEY LAW FIRM 2726 Bissonnet, Ste. 240 PMB 12 Houston, Texas 77005 (281) 652-5973 - fax Attorney for Plaintiff /s/ Emma C. Mata Emma C. Mata EXHIBIT A No. 01-14-01026-CV IN THE COURT OF APPEALS OF TEXAS FOR THE FIRST DISTRICT HOUSTON, TEXAS ENSIGN SERVICES, LLC (F/K/A FE SERVICES, L.L.C.), FE SERVICES HOLDINGS, INC., AND JAMES STEWART, Appellants, V. MARC JAN LEVESCONTE Appellee. Appealed from the 333rd District Court of Harris County, Texas, Cause No. 2009-04966 EMMA C. MATA'S MOTION PURSUANT TO RULE XIX(B) OF THE RULES OF GOVERNING ADMISSION TO THE BAR OF TEXAS TO THE HONORABLE COURT OF APPEALS OF TEXAS FOR THE FIRST DISTRICT OF HOUSTON, TEXAS: Emma C. Mata respectfully files her motion pursuant to Rule XIX(b) of the Rules of Governing Admission to the Bar of Texas in support of Appellants Ensign Services, L.L.C. (f/k/a FE Services, L.L.C.), FE Services Holdings, Inc., and James Stewart ("Appellants") Unopposed Motion for Pro Hac Vice Admission of James M. Harris. The undersigned counsel hereby finds that Mr. Harris is a reputable attorney and move that Mr. Harris be granted permission to participate in this matter before this Court. WHEREFORE, Emma C. Mata, on behalf of Appellants, hereby respectfully request that this Motion be granted and grant such other and further relief as is just and appropriate under the circumstances. Respectfully submitted, / s I Emma C. Mata Emma C. Mata Tex. Bar No. 24029470 emata@seyfarth.com SEYFARTH SHAW LLP 700 Milam, Suite 1400 Houston, Texas 77002 Telephone: (713) 225-2300 Telecopier: (713) 225-2340 Attorneys for Appellants Ensign Services, LL C (f/ k/ a FE Services, LL C.), FE Services Holdings, Inc., and James Stewart EXHIBIT B Board of Law Examiners Appointed by the Supreme Court of MVO Non-Resident Acknowledgment Letter June 03, 2015 JAMES MICHAEL HARRIS SEYFARTH SHAW LLP 2029 CENTURY PARK EAST 3500 LOS ANGELES CA 90067-3021 Application Received: 6/3/15 Causeiroxas Court of Record; 01-14-01026-CV COURT OF APPEALS FOR THE 1ST DISTRICT FROM: Angus Tilney, Licensure Analyst, 512-463-5409 This letter acknowledges receipt of your Application for Pro Hac Vice admission and serves as your Proof of Payment of Fee. Filing the Application for Pro Hac Vice Admission and fee is the mandatory first step in your request for permission to participate in proceedings in a Texas Court. The next step is to file a sworn motion, in compliance with Rule XIX of the current Rules Governing Admission to the Bar of Texas, in the Texas Court in which you request to participate, which must be accompanied by this acknowledgment letter, The decision to grant or deny your application is ultimately made by the Texas Court in which you request to participate. AddresA Street Address Post Office Box 13486 Telephone: 512-Afi3-I 621 Facsimile: 112.46).5300 Wel:Silt: www.ble.stata.lk.te 20.5 Went 14th Street, 5th Floor Austin, Texas 78 71 1-3486 Austin, Texan 78701 --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4056623. Public record. Not legal advice.