Plaintiff’s Unopposed Motion for Leave Regarding Local Counsel Pg 1 of 3

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

Mitchell Ryan

Plaintiff,

v.

Grapevine-Colleyville Independent School 

District and Jorge Rodriguez in his official 

capacity as GCISD School Board President

Defendants.

Civil Action No. 4:21-cv-01075-P

Plaintiff’s Unopposed Motion for Leave to Proceed Without Local Counsel

Comes Now Plaintiff Mitchell Ryan and files this unopposed motion for leave to proceed 

without local counsel pursuant to L.R. 83.10.

Plaintiff’s counsel has conferred with counsel for Defendants and the Defendants are 

unopposed to the grant of this motion.

Plaintiff’s counsel maintains his principal office in Williamson County, Texas, located two 

hours and forty minutes from the Court. Plaintiff’s counsel is available and willing to travel to 

Tarrant County as necessary to attend hearings and other local matters. Any local counsel assigned 

to the case would likely be superfluous as Plaintiff’s counsel intends to be present for any hearing 

or other proceeding in this case. Plaintiff’s counsel has represented clients in the Northern District 

before without local counsel upon grant of leave and is familiar with the Local Rules.

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Plaintiff’s Unopposed Motion for Leave Regarding Local Counsel Pg 2 of 3

Requiring Plaintiff to identify and retain local counsel would impose a significant and 

unnecessary financial hardship on Plaintiff. Additionally, because this matter involves a public 

interest client filing suit against a local government and a local government official, Plaintiff 

expects that it may be difficult to locate an additional attorney.

Accordingly, Plaintiff moves for leave pursuant to L.R. 83.10 in order to proceed without 

local counsel. If this Motion is denied, Plaintiff requests up to 14 days following denial of the 

motion in order to attempt to locate and secure local counsel who is willing to participate on 

Plaintiff’s behalf in this matter.

Respectfully submitted,

The Law Offices of Tony McDonald

By: /s/ Tony McDonald 

Tony McDonald

Attorney at Law

State Bar No. 24083477

1501 Leander Dr., Suite B-2

Leander, TX 78641

(512) 200-3608 (office)

(512) 923–6893 (mobile)

(815) 550–1292 (fax)

tony@tonymcdonald.com

Counsel for Plaintiff

Dated September 22, 2021

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Plaintiff’s Unopposed Motion for Leave Regarding Local Counsel Pg 3 of 3

Certificate of Conference

On September 22, 2021, I conferred with counsel for Defendants over email who stated 

that Defendants do not oppose this motion.

Certificate of Service

I certify that on September 22, 2021, I electronically submitted the forgoing document with 

the Clerk of the Court for the U.S. District Court for the Northern District of Texas, using the 

CM/ECF system of the Court. The electronic case filing system sent “Notice of Electronic Filing” 

to individuals who have consented in writing to accept this notice of service by electronic means. 

I also certify that I sent a copy of this document to counsel for Defendants by electronic mail:

Joseph F. Cleveland

Brackett & Ellis, P.C.

100 Main Street

Fort Worth, TX 76102

817.339.2454 (Direct)

817.870.2265 (Fax)

jcleveland@belaw.com

Sarah S. Flournoy

Brackett & Ellis, P.C.

100 Main Street

Fort Worth, TX 76102

817.339.2417 (Direct)

817.870.2265 (Fax)

sflournoy@belaw.com

September 22, 2021

/s/ Tony K McDonald

Tony K McDonald

Counsel for Plaintiff

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