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 FILED IN
FOR THE STATE OF TEXAS 1st COURT OF APPEALS
HOUSTON, TEXAS
______________________________________________________________________________________________________________________________________________________________________________________________________
3/6/2015 11:35:52 AM
In re TMX Finance of Texas, Inc.; TitleMax of
Texas, Inc.; and TMX Finance LLC CHRISTOPHER Clerk
A. PRINE
______________________________________________________________________________________________________________________________________________________________________________________________________
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 152nd Judicial District Court of Harris County,
Texas. My pro hac vice application to appear in that case was approved by the
152nd 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
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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
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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
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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
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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
GREENBURG TRAURIG, 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
BECK REDDEN LLP
1221 McKinney St., Suite 4500
Houston, Texas 77010
(Attorneys for Relator TMX Finance, LLC)
/s/ Daniel Johnson
Daniel Johnson
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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
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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_ _ _ __
2015 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.
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 exas
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
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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· S1~-.: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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