Gramercy Advisor LLC, Gramercy Asset Management LLC, Gramercy Local Markets Recovery Fund LLC and Gramercy Financial Services LLC v. R. K. Lowery, Jr. L-Falling Creek LLC, Russell A. Chabaud, R-Rac Wimbledon, LLC, John P. Moffitt, J-Jason LLC, Russell A. Chabaud, Trustee of the Russell G. Chabaud 1999 Investment Trust, R- Russell Wimbledon, LLC

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ACCEPTED 01-14-00904-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 12/29/2014 10:35:32 AM CHRISTOPHER PRINE CLERK NO. 01-14-00904-CV FILED IN IN THE FIRST COURT OF APPEALS 1st COURT OF APPEALS HOUSTON, TEXAS HOUSTON, TEXAS 12/29/2014 10:35:32 AM CHRISTOPHER A. PRINE Clerk GRAMERCY ADVISORS LLC, ET AL, Appellants vs. R.K. LOWRY, JR., ET AL., Appellees. Interlocutory Appeal from the 80th Judicial District Court, Harris County, Texas Cause No. 2008-74262 MOTION IN SUPPORT OF DANIEL M. HIBSHOOSH’S MOTION FOR ADMISSION PRO HAC VICE TO THE HONORABLE JUDGE OF SAID COURT: Pursuant to Rule XIX of the Rules Governing Admission to the Bar of Texas, Defendants Gramercy Advisors, LLC, Gramercy Asset Management, LLC, Gramercy Local Markets Recovery Fund LLC, and Gramercy Financial Services, LLC; (collectively, "Appellants"), and the undersigned resident attorney, David C. Mattka, counsel for the Appellants, respectfully request that this Court admit pro hac vice Daniel M. Hibshoosh, an attorney in good standing of the Bar of the State of New York, to represent the Appellants in this matter. In support of this Motion, the undersigned represents that good cause exists to permit Mr. Hibshoosh to be 1 admitted pro hac vice on the Appellants’ behalf, and would respectfully show the Court as follows: 1. Daniel M. Hibshoosh is an attorney with the law firm of O'Shea Partners LLP, 521 Fifth Avenue, 25th Floor, New York, New York 10175, telephone number (212) 682-4426, facsimile number (212) 682-4437, and e-mail dhibshoosh@osheapartners.com. 2. Daniel M. Hibshoosh and O'Shea Partners, LLP are counsel to the Appellants and have represented them in litigation in other courts. 3. The Appellants request that Daniel M. Hibshoosh represent them in this matter because of Mr. Hibshoosh’s knowledge and prior experience representing the Appellants, along with the ongoing presence and assistance of the undersigned, David C. Mattka, who is an attorney in good standing and duly licensed to practice in the State of Texas. 4. Resident attorney David C. Mattka and the law firm of Munsch Hardt Kopf & Harr, P.C. will continue to represent the Appellants at all proceedings in this matter and will assume full responsibility for all papers filed with this Court and for the conduct of the case and of the attorneys admitted pro hac vice. 5. Attached hereto as Exhibit 1 is the Motion for Admission Pro Hac Vice filed by Daniel M. Hibshoosh. Attached as Exhibit A thereto is the Non- 2 Resident Acknowledgement Letter issued to Mr. Hibshoosh by the Texas Board of Law Examiners. 6. The undersigned Texas resident attorney, David C. Mattka, finds Applicant Daniel M. Hibshoosh to be a reputable attorney and recommends that Applicant Daniel M. Hibshoosh be granted permission to participate in this particular proceeding before this Court. Thus, it is respectfully requested that Daniel M. Hibshoosh be admitted pro hac vice to represent the Appellants in this proceeding. 3 Dated: December 29, 2014 Respectfully submitted, MUNSCH HARDT KOPF & HARR, P.C. By: /s/ David C. Mattka____________ David C. Mattka (TSB No. 13231500) 401 Congress Avenue, Suite 3050 Austin, Texas 78701 (512) 391-6100 (telephone) (512) 391-6149 (facsimile) dmattka@munsch.com Lead Counsel for Appellants 4 CERTIFICATE OF SERVICE As required by Texas Rule of Appellate Procedure 6.3 and 9.5, I certify that I have served this document on all parties, which are listed below, on December 29, 2014 as follows: David R. Deary via e-filing and email davidd@lfdlaw.com W. Ralph Canada, Jr. ralphc@lfdlaw.com Wilson Wray wilsonw@lfdlaw.com Tyler Simpson tylers@lfdlaw.com Lowsinsohn Flegel Deary, LLP 12377 Merit Drive, Suite 900 Dallas, Texas 75251 /s/ David C. Mattka David C. Mattka 5 MHDocs 5825013_1 10862.1