Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 3/6/2015 11:35:52 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00126-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 3/6/2015 11:35:52 AM CHRISTOPHER PRINE CLERK No. 01-15-00126-CV IN THE FIRST COURT OF APPEALS FOR THE STATE OF TEXAS ______________________________________________________________________________________________________________________________________________________________________________________________________ In re TMX Finance of Texas, Inc.; TitleMax of
Texas, Inc.; and TMX Finance LLC ______________________________________________________________________________________________________________________________________________________________________________________________________
Original Proceeding from the 152nd Judicial District Court, Harris County, Texas, Trial Court Cause No. 2013-33584, the Honorable Robert Schaffer, Presiding Judge UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF
SARAH POWERS
I, Sarah Powers, under the authority of the Rules Governing Admission to
the Bar of Texas, Rule XIX, and of the Texas Rules of Appellate Procedure, Rule
10, file this Unopposed Motion for Pro Hac Vice Admission to appear before the
Court.
I. FACTS 1. I am associated with Daniel Johnson, who will personally participate
in the trial of this case. Daniel Johnson is a practicing attorney and a member of
the State Bar of Texas. His State Bar card number is 24046165; his office address,
telephone number, and facsimile number are: Sutherland Asbill & Brennan LLP,
1001 Fannin Street, Suite 3700, Houston, Texas 77002-6760, Telephone (713)
470-6100, Facsimile: (713) 654-1301.
2. I am a member in good standing of the State Bar of California.
3. 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.
4. I have not been denied admission to the courts of any state or to any
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 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.
6. I have appeared or sought leave to appear in any Texas court in the
last two years, specifically: 1) Cause No. 2013-33584; Wellshire Financial
Services, LLC d/b/a LoanStar Title Loans d/b/a MoneyMax Title Loans, and d/b/a
LoanMax; Meadowwood Financial Services, LLC d/b/a LoanStar Title Loans, and
d/b/a MoneyMax Title Loans; and Integrity Texas Funding, LP, Plaintiffs, vs. TMX
Finance Holdings, Inc.; TMX Finance, LLC; TMX Finance of Texas, Inc.; and
TitleMax of Texas, Inc. ; in the 152 nd Judicial District Court of Harris County,
Texas. My pro hac vice application to appear in that case was approved by the
152 nd Judicial District Court of Harris County, Texas, on March 26, 2014; and 2)
Cause No. 01-14-00964; In re TMX Finance of Texas, Inc.; TitleMax of Texas,
Inc.; and TMX Finance LLC – In the Court of Appeals for the First District of
Texas. My pro hac vice application to appear in that case was granted by the First
Court of Appeals on December 23, 2014.
7. My office address, telephone number, and facsimile number are
Wargo French, LLP, 1888 Century Park East, Suite 1520, Los Angeles, California;
Telephone: (310) 853-6300, and Facsimile: (310) 853-6333.
8. Attached hereto is my Proof of Payment of Fee from the Texas Board
of Law Examiners.
II. PRAYER For these reasons, Sarah Powers ask this Court to grant her Unopposed
Motion for Pro Hac Vice Admission and to allow her to appear before this Court
until the conclusion of this cause of action.
Respectfully submitted, SUTHERLAND ASBILL & BRENNAN LLP By: /s/ Daniel Johnson Daniel Johnson (SBN 24046165) Robert A. Lemus (SBN 24052225) 1001 Fannin Street, Suite 3700 Houston, Texas 77002 Telephone: (713) 470-6100 Facsimile: (713) 654-1301 E-mail: daniel.johnson@sutherland.com E-mail: robert.lemus@sutherland.com And
WARGO & FRENCH LLP Joseph D. Wargo (GA No. 738764) Abigail Stecker Romero (CA No. 284534) 999 Peachtree Street, N. E., 26th Floor Atlanta, Georgia 30309 Telephone: (404) 853-1500 Facsimile: (404) 853-1501 E-mail: jwargo@wargofrench.com E-mail: aromero@wargofrench.com WARGO & FRENCH LLP Sarah F. Powers (CA No. 238184) ( Pro Hac Vice Admission Pending) Christina L. Goebelsmann (CA No. 273379) 1888 Century Park E, Suite 1520 Los Angeles, California 90067 Telephone: (310) 853-6300 Facsimile: (310) 853-6333 E-mail: spowers@wargofrench.com E-mail: cgoebelsmann@wargofrench.com Attorneys for Real Parties In Interest Wellshire Financial Services, LLC, d/b/a LoanStar Title Loans, d/b/a MoneyMax Title Loans, and d/b/a LoanMax; Meadowwood Financial Services, LLC, d/b/a LoanStar Title Loans, and d/b/a MoneyMax Title Loans; and Integrity Texas Funding, LP *5 CERTIFICATE OF CONFERENCE I, Daniel Johnson, hereby certify that we conferred with counsel for
Defendants on March 5, 2015, concerning the Unopposed Motion for Pro Hac
Vice Admission of Sarah Powers. Counsel for Defendants confirmed that they are
unopposed to the Motion.
/s/ Daniel Johnson Daniel Johnson *6 CERTIFICATE OF SERVICE This is to certify that I have this day served all parties with a copy of the
within and foregoing instrument in accordance with the Texas Rules of Appellate
Procedure 6.3 and 9.5(b), (d), (e), to all counsel of record on this 6th day of March
2015.
Via e-filing
Roland Garcia, Jr.
L. Bradley Hancock
Mary Olga Lovett
Christopher David Johnsen
G REENBURG T RAURIG , LLP
1000 Louisiana, Suite 1700
Houston, Texas 77002
(Attorneys for Relators TMX Finance of Texas, Inc.;
TitleMax of Texas, Inc.)
Via e-filing
David Beck
Geoffrey A. Gannaway
Bryon Rice
B ECK R EDDEN LLP
1221 McKinney St., Suite 4500
Houston, Texas 77010
(Attorneys for Relator TMX Finance, LLC)
/s/ Daniel Johnson Daniel Johnson *7 VERIFICATION STATE OF CALIFORNIA §
§
COUNTY OF LOS ANGELES §
On this day, Sarah Powers, before me the undersigned Notary, after
having been duly sworn upon her oath, deposed and stated that she has read
the within Unopposed Motion for Pro Hac Vice Admission, and that the
above-mentioned facts are true based upon her knowledge, information, and
belief.
Dated: March 2 , 2015
SWORN TO AND SUBSCRIBED before me by Sarah Powers on this
__ day of March 2015.
Notary Public in and for the State of California *8 JURAT A notary public or other officer completing this certificate verifies only the
identity of the individual who signed the document to which this certificate
is attached, and not the truthfulness, accuracy, or validity of that document.
State of California
County of Los Angeles
Subscribed and sworn to (or affirmed) before me on this 2nd day of -"'M,a,_,rc"-'h ____ _ by Sarah Fleisig Powers
proved to me on the basis of satisfactory evidence to be the person(s) who appeared
before me.
OPTIONAL INFORMATION INSTRUCTIONS The wording of alf Jurats completed in California after January 1, 2015 must be in the form as set forth within this Jurat. There are no exceptions. If a Jurat to be completed does not follow this form, the notary must correct the verbiage by using a jurat stamp
containing the correct wording or attaching a separate jurat form such as this one with does contain the proper wording. In addition, the notary must require an oath or DESCRIPTION OF THE ATTACHED DOCUMENT affirmation from the document signer regarding the truthfulness of the contents of the document. The document must be signed AFTER the oath or affirmation. If the document Application for Pro Hav Vice Admission was previously signed, it must be re-signed in front of the notary public during the jurat (Title or description of attached document) process. State and county information must be the state and county where the document signer(s) personally appeared before the notary public. (Title or description of attached document continued) Date of notarization must be the date the signer(s) personally appeared which must also be the same date the jurat process is completed. Number of Pages __ Document Date, ___ _ Print the name(s) of the document signer(s) who personally appear at the time of notarization. • Signature of the notary public must match the signature on file with the
Additional information office of the county clerk.
• The notary seal impression must be clear and photographically reproducible. Impression must not cover text or lines. If seal impression smudges, re-seal if a sufficient area permits, otherwise complete a different jurat form. ·!· Additional information Is not required but could help to ensure this jurat is not misused or attached to a different document. •!• Indicate title or type of attached document, number of pages and date. 2015 Version www.NotaryCiasses.com 800-873-9865 Securely attach this document to the signed document with a staple.
*9 03-05-2015 I 0:50am From- T-273 P 002/002 F-977
Board of Law Examinel"s Appointed by the Suprcm~ Court ofT ex as Non-Resident Acknowledgment Letter March 05, 2015 SARAH FLEISIG POWERS
WARGO FRENCH LLP
1888 CE::-lTURY PARK EAST SUITE 1520
LOS At\GELES CA 90067-
Application Received: 03/05/15
Cause/Texas Court ofRecord: CAUSE NO: 01-15-00126-CV COURT OF APPEALS FOR FIRST DISTRIC{ HOU
FROM: Julie Lukenbill, Licensure Analyst, 512-463-2684 !
This letter acknowledges receipt of your Application for Pro Hac Vice admission and serves as
your Proof of Paymen1: 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 cunent 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 grantor deny your application is
ultimately made by the Texas Coc1rt in which you request to participate.
Mailing Addre:!\~ Stttt:I Addr~"' Pos.t Ofiieo:: Box 13·186 Tele(lbntlO' ~ 1::!:-M.l-IIP..! fj~AiH•i!h· S 1~-.:f..l-'i\Of'l Wut>"ito:o "'"""' '11e nn(~ 1X \•g J05 Wdl t4~h Sire~;~, Slit f!Qpr
Austin, Texas 78711·3486 Aus~in, Tt:X!l:> 78701 i
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