Urika Bjorkstam and Joseph Daniel Drey v. Woodward, Inc.

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ACCEPTED 14-14-00927-cv FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 4/6/2015 1:47:18 PM CHRISTOPHER PRINE CLERK No. 14-14-00927-CV __________________________________________ FILED IN 14th COURT OF APPEALS IN THE FOURTEENTH COURT OF APPEALSHOUSTON, AT TEXAS HOUSTON, TEXAS 4/6/2015 1:47:18 PM CHRISTOPHER A. PRINE _______________________________________ Clerk ULRIKA BJORKSTAM AND JOSEPH DANIEL DRAY, Appellants, v. WOODWARD, INC., Appellee. _____________________________________________________ On Appeal from the 190th Judicial District Court of Harris County, Texas Trial Cause No. 2010-31214 __________________________________________________________ UNOPPOSED MOTION OF NON-RESIDENT ATTORNEY, JOHN MICHAEL KELLY, FOR ADMISSION PRO HAC VICE _______________________________________________________________ TO THE HONORABLE FOURTEENTH COURT OF TEXAS: John Michael Kelly (“Applicant”) files this Unopposed Motion of Non- Resident Attorney for Admission Pro Hac Vice, and would show the Court as follows: 1. Applicant seeks permission to appear pro hac vice as counsel for Appellee, Woodward, Inc., in the above-entitled and numbered appeal. 2. Applicant is a Partner with the law firm of Adler Murphy & McQuillen LLP, 20 South Clark Street, Suite 2500, Chicago, Illinois 60603. 3. Applicant will be associated in this proceeding with N. Terry Adams, Jr., a resident attorney whose Texas State Bar Number is 00874010. N. Terry Adams, Jr. is a licensed attorney who practices with the law firm of: BEIRNE, MAYNARD & PARSONS, L.L.P. 1300 Post Oak Blvd., Suite 2500 Houston, Texas 77056 (713) 623-0887 Tel (713) 960-1527 Fax 4. N. Terry Adams, Jr. has conferred with John C. Schwambach, Jr., counsel for Appellants, on March 23, 2015, who advised that Appellants are not opposed to the Applicant’s motion for admission pro hac vice. 5. Applicant is an active member in good standing with the State of Illinois and multiple federal courts. 6. Pursuant to Texas Rules Governing Admission to the Bar of Texas, Rule XIX (a), Applicant has filed an Application for Admission Pro Hac Vice with the Texas Board of Law Examiners and paid the $250 filing fee. The Texas Board of Law Examiners’ letter acknowledging the application is attached to this motion as Exhibit A and incorporated by reference. 7. Applicant has not been the subject of any disciplinary actions by the Bar or courts of any jurisdiction in which Applicant is licensed during the past five years. 2 8. Applicant attests that he is familiar with the State Bar Act, the State Bar Rules, and the Texas Disciplinary Rules of Professional Conduct governing the conduct of members of the State Bar of Texas. Applicant attests that he will at all times abide by and comply with these rules as long as the Texas proceeding is pending and he has not withdrawn as counsel in the proceeding. 9. Applicant has not appeared in any civil appellate case in Texas within the last two years. WHEREFORE, John Michael Kelly respectfully requests that the Court grant this motion, and enter an order allowing Applicant to participate as one of the attorneys for Woodward, Inc. in the above-titled and numbered appeal. Respectfully submitted, ADLER MURPHY & MCQUILLEN L.L.P. By: /s/ John Michael Kelly John Michael Kelly 20 South Clark Street, Suite 2500 Chicago, Illinois 60603 (312) 345-0700 (Tel) (312) 345-9860 (Fax) jkelly@amm-law.com Counsel for Woodward, Inc. 3 CERTIFICATE OF CONFERENCE This is to certify local counsel N. Terry Adams, Jr. has advised me that on the 23rd day of March, 2015, he contacted John Schwambach, Jr., one of the attorneys for Appellants regarding the contents of this motion. Mr. Schwambach indicated that Appellants do not oppose this motion. /s/ John Michael Kelly John Michael Kelly 4 VERIFICATION STATE OF ILLINOIS On this day, JOHN MICHAEL KELLY appeared before me, the undersigned Notary Public, and after I administered oath to him, upon his oath, he said he read the above Unopposed Motion for Non-Resident Attorney John Michael Kelly, for Admission Pro Hac Vice, and tl the facts stated herein are within his personal knowledge and are true and co ct. John ael Kelly SWORN TO AND SUBSCRIBED BEFORE ME by the said John Michael Kelly on the 2)1)/ day of ribi,,cL, , 2015, to certify which witness may hand and seal of office. - 1)190MnipatJa Notary Public, State of Illinois "OFFICIAL SEAL" Mary F Domagalski Notary Public, State of Illinois My Commission Expires 1 2/4 /2018 5 CERTIFICATE OF SERVICE I hereby certify that the foregoing Unopposed Motion for Non-Resident Attorney, John Michael Kelly, for Admission Pro Hac Vice was electronically filed on this the 6th day of April, 2015, and served on the following appellate counsel of record in accordance with the Texas Rules of Appellate Procedure and the Local Rules of this Court. John C. Schwambach, Jr. Pierce & O’Neill, LLP 4119 Montrose Blvd., Suite 350 Houston, Texas 77006 Counsel for Appellants /s/ John Michael Kelly John Michael Kelly 6 EXHIBIT A 7 2152274v.1 005716/107779 Dato! 9/18/2015 Timat 10!13!48 QM Pam! 2 of 2 Board of Law Examiners Appointed by the Supreme Court of Texas Non-Resident Acknowledgment Letter March 18, 2015 JOHN MICHAEL KET,LY ADLER MURPHY & MCQUILLEN, LLP 20 SOUTH CLARK STREET, STE 2500 CHICAGO IL 60603- Application Received: 03/16/15 Cause/Texas Court of Record: #14-14-00927; 1'OURTEENTI1 COURT OF APPEALS; HOUSTON, TX FROM: April Shaheen, T.icensure Analyst, 512-463-R444 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 Inum.-bc arrnmpanird her this arknrywlrrigmrntlritrr Thr drrisinn to grant nr drny your appliratinn is ultimately made. by theTexas Court in which you request to participate.