MOTION FOR APPROVAL OF EMPLOYMENT OF SPECIAL COUNSEL FOR TRUSTEE - Page 1

Kent Ries, Attorney at Law 

State Bar No. 16914050

PO Box 3100

Amarillo, Texas 79116

(806) 242-7437

(806) 242-7440 – Fax

kent@kentries.com

COUNSEL FOR TRUSTEE

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

AMARILLO DIVISION

IN RE: §

§

MCCLAIN FEED YARD, INC., et al.,1 § CASE NO. 23-20084-RLJ-7

§

§

Debtors. § Jointly Administered

MOTION FOR APPROVAL OF EMPLOYMENT 

OF SPECIAL COUNSEL FOR TRUSTEE

TO THE HONORABLE ROBERT L. JONES, BANKRUPTCY JUDGE:

COMES NOW, Kent Ries, Trustee (“Trustee”) of the referenced Chapter 7 bankruptcy 

estates, and files this Motion for Approval of Employment of Special Counsel for Trustee, and in 

support thereof would respectfully show unto the Court as follows:

1. Debtors filed for relief under Chapter 7 of the United States Bankruptcy Code on 

April 28, 2023. Kent Ries was subsequently appointed and qualified to serve as the Trustee over the

bankruptcy estate.

2. Trustee asserts it is necessary to employ special counsel, pursuant to 11 U.S.C. § 

327, to perform necessary legal services in obtaining and investigating records and information 

of the Debtors, and investigating and pursuing litigation claims of the Debtors’ bankruptcy 

estates. These cases pose substantial challenges recreating financial records of the Debtors and 

1 The Debtors in these Chapter 7 cases are: McClain Feed Yard, Inc. (Case No. 23-20084-RLJ), McClain Farms, Inc. 

(Case No. 23-20085-RLJ), and 7M Cattle Feeders, Inc. (Case No. 23-20086-RLJ)

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MOTION FOR APPROVAL OF EMPLOYMENT OF SPECIAL COUNSEL FOR TRUSTEE - Page 2

reviewing such information for potential litigation against numerous parties in Texas, Kentucky 

and likely other states where the Debtors’ conducted business. The Debtors’ records appear to 

be poor and unreliable. The Debtors’ losses, based on estimated creditor claims, exceed well 

over 100 million dollars. The Trustee has spent considerable time investigating professionals

that have prior experience in similar cases and have current capabilities to provide the Trustee 

with a litigation plan to identify and recover potential claims of the estate.

3. Trustee desires that he be authorized to employ the law firm of Quilling, Selander, 

Lownds, Winslett & Moser, 2001 Bryan Street, Suite 1800, Dallas, TX 75201 (the “Quilling 

Firm”), with Hudson Jobe as the primary counsel, and to pay the firm such compensation and 

reimbursement of expenses as is just pursuant to 11 U.S.C. § 330 and Rule 2016 of the Federal 

Rules of Bankruptcy Procedure. Hudson Jobe’s declaration as required by 11 U.S.C. § 327 is 

attached hereto as Exhibit A and incorporated herein by reference for all purposes. As set forth in 

the declaration, prior to these Chapter 7 filings, Hudson Jobe discussed with the Debtors’ CRO a 

possible representation of the Debtors in filing Chapter 11 bankruptcy cases, but was never 

formally retained and the Debtors chose not to move forward on Chapter 11 filings. Trustee and 

Mr. Jobe believe that these communications do not present any conflict issues with Mr. Jobe’s 

engagement as special counsel given the specific authorization for same under section 327(e).

2

4. The normal rate for legal services provided by Hudson Jobe is $525.00 per hour, 

plus out-of-pocket expenses. Although it is planned for Hudson Jobe to be the primary counsel

in this matter, it is likely other attorneys or paralegals of the Quilling Firm may also work on this 

2 The trustee, with the court’s approval, may employ, for a specified special purpose, other than to represent the 

trustee in conducting the case, an attorney that has represented the debtor, if in the best interest of the estate, and if 

such attorney does not represent or hold any interest adverse to the debtor or to the estate with respect to the matter 

on which such attorney is to be employed.

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MOTION FOR APPROVAL OF EMPLOYMENT OF SPECIAL COUNSEL FOR TRUSTEE - Page 3

matter under the direction of the Trustee. The range of fees for such professionals is outlined in

the engagement letter attached hereto as Exhibit B and incorporated herein for all purposes.

5. The Quilling firm typically requests a retainer for similar engagements. The 

Quilling Firm will file a separate motion regarding a retainer agreement with appropriate notice

and hearing on same. 

6. As set forth in the engagement letter, it is anticipated that a substantial amount of 

fees and expenses in this engagement will be individual tasks or expenses that benefit more than 

one of the Debtor’s bankruptcy estates. For those fees and expenses, the firm will utilize a single 

billing invoice, and all three Debtors’ estates will be jointly and severally liable for those fees 

and expenses. For fees and expenses that are clearly relevant to only one of the Debtor’s estates, 

the firm will bill those fees and expenses on a separate invoice for that particular Debtor’s estate, 

and only the specific Debtor’s estate will be responsible for this separate invoice. However, the 

firm reserves the right to seek Bankruptcy Court approval of payment of separate fees and 

expenses from other Debtor’s estates in the event such fees and expenses have benefited other 

Debtor’s estates. 

WHEREFORE, PREMISES CONSIDERED, Kent Ries, Trustee herein, respectfully 

prays for an Order of this Court approving the employment the Quilling Firm to perform 

professional legal services in these cases, and for such other relief, at law or in equity, to which 

the Trustee may show himself justly entitled.

Respectfully submitted,

Kent Ries, Attorney at Law

PO Box 3100

Amarillo, Texas 79116

(806) 242-7437

(806) 242-7440-Fax

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MOTION FOR APPROVAL OF EMPLOYMENT OF SPECIAL COUNSEL FOR TRUSTEE - Page 4

By: /s/ Kent Ries

 Kent Ries

 State Bar No. 1691450

COUNSEL FOR TRUSTEE

CERTIFICATE OF SERVICE

I hereby certify that on the 30th day of June 2023, a true and correct copy of the above 

and foregoing Motion was sent electronically via the Court’s ECF system on the United States 

Trustee and parties requesting service. 

 /s/ Kent Ries 

Kent Ries 

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EXHIBIT “A”

THE STATE OF TEXAS §

§ KNOW ALL MEN BY THESE PRESENTS:

DALLAS COUNTY §

DECLARATION OF HUDSON JOBE

1. I am a resident of Dallas, Dallas County, Texas; am over the age of 21 years and 

am of sound mind and have never been convicted of an offense.

2. I am an attorney admitted to practice in the State of Texas, and possess all of the 

qualifications of an attorney in the State of Texas. 

3. I have reviewed the Motion by the Trustee for approval to retain my firm as special 

counsel in these Chapter 7 bankruptcy cases. I am an attorney admitted to practice with extensive 

knowledge and experience in the type of litigation at issue in the Motion and am in all respects 

qualified to render the necessary legal services requested by the Trustee.

4. Prior to the Debtors’ chapter 7 filings, I discussed a possible representation of the 

Debtors to file Chapter 11 bankruptcy cases with the Debtors’ CRO, Glenn Karlberg. I was never 

formally retained and the Debtors chose not to move forward on Chapter 11 filings. 

5. I have run a conflict search for my firm of the parties set forth on the attached 

conflict list, which was compiled from the matrix in the Debtors’ bankruptcy cases. Two hits came 

back from that search - Douglas Pritchett and Purina Animal Nutrition LLC. The firm is currently 

acting as receiver in a case in Hunt County, Texas involving a Douglas Pritchett. I am unaware if 

this is the same individual listed in the bankruptcy matrix in this case. Pending further 

investigation, my firm will not represent the Trustee in any matter directly adverse to Douglas 

Pritchett unless it is determined to be a different individual. With respect to Purina Animal 

Nutrition LLC, the firm represented this company in a real estate title issue that concluded more 

than a year ago, and believed to not involve property related to the Debtors. 

6. Except as set forth above, based upon this search and my current understanding of 

the parties in these bankruptcy cases, I am not aware of any prior or current representations of 

my law firm of any of these parties. Accordingly, to the best of my knowledge and belief, 

Quilling, Selander, Lownds, Winslett & Moser is disinterested and has no connection with the 

Debtor, creditors of the estate, any party in the United States Trustee’s office or any other 

parties. Similarly, to the best of my knowledge and belief, Quilling, Selander, Lownds, Winslett 

& Moser does not have an interest adverse to the Estate.

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Dated June 30, 2023.

/s/ Hudson M. Jobe

Hudson Jobe

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CONFLICT LIST

Brian McClain

Rabo AgriFinance

Mechanics Bank

MAP Enterprises

Wild Horse Cattle Co. 

(Kentucky entities)

Community First Bank in 

Kentucky

2B Farms

AJ Jacques Living Trust

Arnold Braun

Arnold Braun Trust

Dr. Arnold Braun

Buss Family Trust

Caterpillar Financial 

Services Corporation

First Kentucky Bank

Gene Brookshire Family, 

LP

Gray Brothers

Gungoll Cattle LLC

Jordan Lesh, LLC

Lesh Family Trust

Morrison Café LLC

Northland Capital 

Financial Services LLC

Scarlet and Black Cattle 

LLC

Scott Livestock Company 

Inc.

Steve T. Scott Farms, Inc.

W. Robbie Russell Living 

Trust

Acey Livestock LLC

Ag Texas Farm Credit 

Services

AgTexas, PCA

Angela Powell

Bar D Ranch Land & 

Cattle LLC

Big Seven Capital Partners 

LLC

Bo Robinson

Bryan Blackman

C Heart Ranch LLC

Cactus Feeders Finance 

LLC

Cactus Operating LLC

Caleb Little

Carl Pickett

Carraway Cattle

Chelsea Waters McClain

Kentucky Department of 

Agriculture

Cody L. Simmons

Colton Long

Community Financial 

Services Bank

Cory Don Priest

Crystal McClain

Curtis Jones

Curtis Jones Farms LLC

David Rainey

Death Creek Farms LLC

Don Jones

Don Jones Farm Inc.

Don Jones Trucking Inc.

Douglas Pritchett

Dwight Jesko

Eric Dejarnatt

First Capital Bank of 

Texas

First Kentucky Bank

Friona Industries, L.P.

Frontier Farm Credit

Garwood Cattle Company 

LLC

Hines Cattle Company 

LLC

Hines Farms LLC

J. Brent Burnett

Jake Rininger

Jared Lesh Cowhorses Inc.

Jared Wayne Lesh

Jed Goad

JLE Trucking, Inc.

Jimmy D. Greer

John Dale Tidwell

Jordan Robert Lesh

Jordan and Jan Lesh

Julie Whitlock

Justin Stuever

Keeling Cattle Feeders, 

Inc.

Keith Harris Farms, Inc.

Kenneth Netardus

Kinsey Jones

Lazy J Arena, LLC

Lazy J Cattle

Lesh Family Trust

Lesh Trucking

Lyndal Van Buskirk

Meagan B. Goad

Meagan B. Powell

Michael Gourley

Mykel Linn Tidwell

Oklahoma AgCredit

Open A Arena LLC

Patty Priest

Priest Cattle Company, 

Ltd.

Priest Cattle and Land 

Company, Inc.

Priest Victory Investment 

LLC

Producers Credit 

Corporation

Rapp Ranch

Rick Rodgers

Riley Livestock

Robert Braun

Samuel S. Brown

Shaw & Shaw Farms 

Partnership,LLC

Sherman Trucking

Stanley Ayers

TGF Ranch

Takeuchi Financial 

Services

Terry Burnett

Thorlakson Feedyards

Tom Thorlakson

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WJ Performance Horses, 

Inc.

Wildforest Cattle 

Company LLC

Amy Sutton

Charles Lockwood

Colby Van Buskirk

Cole Lockwood

Craig Sutton

Don Hines

Dennis Buss

Dora Blackman

Douglas Finley

Dustin Johnson

Eddie Bryant

Eddie Stewart

Gary Lesh

Janet Van Buskirk

Janice Lawhon

Joel Brookshire

Leah Gungoll

Michael Evans

Miranda Evans

Nikki Lockwood

Robert Spring

Robert Gray

Robert & Rachel Steward

Ronnie Gray

Sherle Lockwood

Steve Ryan

Steven Hines

Susan Van Buskirk

Wiley Russell, Jr.

Wiley Roby Russell, Jr.

BJM Sales & Service

Heartland Co-Op

Purina Animal Nutrition 

LLC

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