Opinion

Terry Neff and Iron Workers Mid- South Pension Fund v. Nicholas F. Brady, David J. Butters, Willilam E. MacAulay, Robert B. Millard, Robert K. Moses, Jr., Robert a Rayne, Bernard J. Duroc-Danner and Burt M. Martin

Court
Texas Court of Appeals, 1st District (Houston)
Filed
Sep 15, 2015
Status
Published
Cited by
0 cases

The opinion

ACCEPTED

01-15-00544-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

9/15/2015 2:38:29 PM

CHRISTOPHER PRINE

CLERK

No. 01-15-00544-CV

FILED IN

1st COURT OF APPEALS

HOUSTON, TEXAS

3Sn tbe jfir%t q[:ourt of ~ppeal% 9/15/2015 2:38:29 PM

CHRISTOPHER A. PRINE

1!)ou%ton, ZlrexaS' Clerk

TERRY NEFF AND IRON WORKERS Mm-SOUTH PENSION FUND, DERIVATIVELY ON

BEHALF OF WEATHERFORD INTERNATIONAL LTD.,

Appellants,

v.

NICHOLAS F. BRADY, DAVID J. BUTTERS, WILLILAM E. MACAULAY, ROBERT B.

MILLARD, ROBERT K. MOSES, JR., ROBERT A RAYNE, BERNARD J. DUROC-DANNER

AND BRUCE M. MARTIN,

Appellees,

Appeal from the 270th Judicial District Court, Harris County, Texas

GEORGE C. AGUILAR'S UNOPPOSED MOTION

FOR PRO HAC VICE ADMISSION

Joe Kendall (SBN 11260700) George C. Aguilar (CA SBN 126535)

Jamie J. McKey (SBN 24045262) ROBBINS ARROYO LLP

KENDALL LAW GROUP, LLP 600 B Street, Suite 1900

3232 McKinney Avenue, Suite 700 San Diego, CA 92101

Dallas, TX 75204 gaguilar@robbinsarroyo.com

jkendall@kendalllawgroup.com Telephone: (619) 525-3990

jmckey@kendalllawgroup.com Facsimile: (619) 525-3991

Telephone: (214) 744-3000

Facsimile: (214) 744-3015

ATTORNEYS FOR APPELLANTS

I, George C. Aguilar, under the authority of the Rules Governing Admission to

the Bar of Texas, Rule XIX, file this Unopposed Motion for Pro Hae Vice Admission

to appear before the Court.

I. FACTS

1. As a mandatory initial requirement, I have complied with the

requirements of Texas Government Code §82.0361 concerning payment of a non-

resident attorney fee to the Board of Law Examiners. A true and correct copy of the

Non-Resident Acknowledgment Letter is attached hereto as Exhibit A.

2. I am associated with Jamie J. McKey of Kendall Law Group, who will

personally participate in the proceedings of this case. Jamie J. McKey is a practicing

attorney and a member of the State Bar of Texas. Ms. McKey's State Bar card number

is 24045262 and her office address, telephone number, and facsimile number are:

Kendall Law Group, LLP, 3232 McKinney Avenue, Suite 700, Houston, Texas

75204, Telephone: (214) 744-3000, Facsimile: (214) 744-3015.

3. I am an active member in good standing of the following jurisdictions:

State of California; U.S. District Court for the Northern, Central, and Southern

Districts of California; U.S. District Court for the Eastern District ofWisconsin; U.S.

District Court for the District of Colorado; and the U.S. Court of Appeals for the

Second, Ninth, and Tenth Circuits.

1

4. I have not been the subject of disciplinary action in the last five years by

the bar or courts of any jurisdiction in which I am licensed.

5. I have not been denied admission to the courts of any state or to any

federal court during the last five years.

6. I am familiar with the State Bar Act, the State Bar Rules, and the Texas

Disciplinary Rules of Professional Conduct governing conduct of members of the

State Bar of Texas, and I will abide by and comply with those rules as long as this

cause of action is pending.

7. I have appeared or sought leave to appear in the following Texas State

courts in the last two years:

(a) Neff v. Brady, et al., Cause No. 2010-40764, 270th Judicial

District, Harris County, Texas;

(b) Phillips, et al. v. Durham, et al., Cause No. 10-07655, 134th

Judicial District, Dallas County, Texas;

(c) Pierce v. Stephenson, et al., Cause No. DC-14-13645, 193rd

Judicial District, Dallas County, Texas;

(d) Richardson v. Newman, et al., Cause No. 2013-00623, 333rd

Judicial District, Harris County, Texas; and

(e) Richardson v. Newman, et al., No. 01-13-00757-CV, First Court of

Appeals, Houston, Texas.

2

8. My office address, telephone number, and facsimile number are Robbins

Arroyo LLP, 600 B Street, Suite 1900, San Diego, California 92101, Telephone: (619)

- 525-3990, Facsimile: (619) 525-3991.

II. PRAYER

For these reasons, I ask this Court to grant my Unopposed Motion for Pro Hae

Vice Admission and to allow me to appear before this Court until the conclusion of

this cause of action.

Dated: September 3, 2015 Respectfully submitted,

Attorneys for Appellants

CERTIFICATE OF CONFERENCE

As required by Texas Rule of Appellate Procedure 10.l(a)(5), I hereby certify

that counsel for Appellants conferred with counsel for Appellees regarding George C.

Aguilar's Motion for Pro Hae Vice Admission. Counsel for Appellees confirmed that

Appellees do not oppose the motion.

3

AFFIDAVIT

STATE OF CALIFORNIA )

) ss.:

COUNTY OF SAN DIEGO )

Comes now George C. Aguilar, oflawful age, being first duly sworn, and states

for his affidavit supporting the within Unopposed Motion for Pro Hae Vice Admission

that the above-mentioned facts are true based upon his knowledge, information, and

belief.

/g

Sworn to and subscribed before me thiO/Jciay of Septenr er, 2~} .

Notary Public

My commission expires:

SUSAN E. MOLINA

. Comml11lon ti 2089726

A notary public or other officer completing ; Nollry Publlc • C1llfornl1

this certificate verifies only the identity of the J• Sin Diego County ..

individual who signed the document to which •• .-•• JU STT· !•t '! J:c lJt tl

0 1 1 1

this certificate is attached, and not the

truthfulness, accuracy, or validity of that

document.

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CERTIFICATE OF SERVICE

I hereby certify that on September 10,

2015, a true and correct copy of the

foregoing motion was served on the following counsel in the manner indicated:

James A. Reeder, Jr. Rebecca N. Brandt

Jeffrey S. Johnston LATHAM & WATKINS LLP

Stacy M. Neal 811 Main Street, Suite 3700

Nicholas Shum Houston, TX 77002

Stephanie Miller rebecca.brandt@lw.com

VINSON & ELKINS LLP VIA E-FILE AND E-MAIL

1001 Fannin St., Suite 2500

Houston, TX 77002 Peter A. Wald

jreeder@velaw.com LATHAM & WATKINS LLP

jjohnston@velaw.com 505 Montgomery Street, Suite 2000

sneal@velaw.com San Francisco, CA 94111

nshum@velaw.com peter.wald@lw.com

smiller@velaw.com VIA E-FILE AND E-MAIL

VIA E-FILE AND E-MAIL

Kevin H. Metz

N. Scott Fletcher LATHAM & WATKINS LLP

Elizabeth G. Myers 555 Eleventh Street NW, Suite 1000

JONES DAY Washington, DC 20004

717 Texas, Suite 3300 kevin.metz@lw.com

Houston, TX 77002 VIA E-FILE AND E-MAIL

sfletcher@jonesday.com

egmyers@jonesday.com Noelle M. Reed

VIA E-FILE AND E-MAIL Charles W. Schwartz

SKADDEN, ARPS, SLATE,

Robert S. Bennett MEAGHER & FLOM LLP

Ellen Kennedy 1000 Louisiana Street, Suite 6800

HOGAN LOVELLS US LLP Houston, TX 77002

555 Thirteenth Street, NW noelle.reed@skadden.com

Washington, DC 20004 charles.schwartz@skadden.com

robert. bennett@hoganlovells.com VIA E-FILE AND E-MAIL

ellen.kennedy@hoganlovells.com

VIA E-FILE AND E-MAIL

ROBBINS GELLER RUDMAN

&DOWDLLP

TRAVIS E. DOWNS III

BENNY C. GOODMAN III

ERIK W. LUEDEKE

655 West Broadway, Suite 1900

San Diego, CA 92101

5

travisd@rgrdlaw.com

bennyg@rgrdlaw.com

el uedeke@rgrdlaw.com

VIA E-FILE AND E-MAIL

6

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