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Marina Gardens-BDS, LLC v. Houston Specialty Insurance Co.

United States District Court, D. Nevada

March 29, 2019

MARINA GARDENS - BDS, LLC, a Nevada Limited Liability Company; MARINA GARDENS - RAF, a Nevada Limited Liability Company, Plaintiff,
v.
HOUSTON SPECIALTY INSURANCE COMPANY, a Texas Corporation; ENGLE MARTIN & ASSOCIATES, LLC, a Georgia Limited Liability Company; DOES 1-XXX; And ABC CORPORATIONS A-Z; inclusive, Defendants.

         FILING FEE IS $250.00

          VERIFIED PETITION FOR PERMISSION TO PRACTICE IN THIS CASE ONLY BY ATTORNEY NOT ADMITTED TO THE BAR OF THIS COURT AND DESIGNATION OF LOCAL COUNSEL

         Matthew A. Foytlin, Petitioner, respectfully represents to the Court:

         1. That Petitioner is an attorney at law and a shareholder of the law firm of Winsteac PC with offices at 600 Travis Street, Suite 5200, Houston, Texas, 77002, (713) 650-8400, mfoytlin@winstead.com.

         2. That Petitioner has been retained personally or as a shareholder of the law firm by Defendant Houston Specialty Insurance Company ("HSIC") to provide legal representation in connection with the above-entitled case now pending before this Court.

         3. That since April 18, 2008, Petitioner has been and presently is a member in good standing of the bar of the highest Court of the State of Texas where Petitioner regularly practices law. Petitioner shall attach a certificate from the state bar or from the clerk of the supreme court or highest admitting court of each state, territory, or insular possession of the United States in which the applicant has been admitted to practice law certifying the applicant's membership therein is in good standing.

         4. That Petitioner was admitted to practice before the following United States District Courts, United States Circuit Courts of Appeal, the Supreme Court of the United States and Courts of other States on the dates indicated for each, and that Petitioner is presently a member in good standing of the bars of said Courts.

Court

Date Admitted

Bar Number

Massachusetts State Bar

12-16-2002

655253

U.S. District Court, Northern District of Texas

8-2-2010

U.S. District Court Southern District of Texas

2-5-2009

U.S. District Court Eastern District of Texas

2-7-2011

U.S. District Court Western District of Texas

3-24-2011

U.S. District Court, District of Massachusetts

5-29-2003

U.S. District Court, Western District of Oklahoma

8-10-2017

U.S. Court of Appeals, First Circuit

9-19-2013

U.S. Court of Appeals, Fifth Circuit

9-24-2013

         5. That there are or have been no disciplinary proceedings instituted against petitioner, nor any suspension of any license, certificate or privilege to appear before any judicial, regulatory or administrative body, or any resignation or termination in order to avoic disciplinary or disbarment proceedings, except as described in detail below: None.

         6. That Petitioner has never been denied admission to the State Bar of Nevada. (Give particulars if ever denied admission): None.

         7. That Petitioner is a member of good standing in the following Bar Associations: Texas and Massachusetts.

         8. Petitioner has filed application to appear as counsel under Local Rule IA 11-2 (formerly LRIA 10-2) during the past three (3) years in the following matters: None.

         9. Petitioner consents to the jurisdiction of the courts and disciplinary boards of the State of Nevada with respect to the law of this state governing the conduct of attorneys to the same extent as a member of the State Bar of Nevada.

         10. Petitioner agrees to comply with the standards of professional cor.duct required oi the members of the bar of this court.

         11. Petitioner has disclosed in writing to the client that the applicant is not admitted to practice in this jurisdiction and that ...


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