No. 01-15-00126-CV

IN THE FIRST COURT OF APPEALS

FOR THE STATE OF TEXAS ______________________________________________________________________________________________________________________________________________________________________________________________________

In re TMX Finance of Texas, Inc.; TitleMax of

Texas, Inc.; and TMX Finance LLC ______________________________________________________________________________________________________________________________________________________________________________________________________

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.

ACCEPTED

01-15-00126-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

3/6/2015 11:35:52 AM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 3/6/2015 11:35:52 AM CHRISTOPHER A. PRINE Clerk
2

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
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 

7 
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 

DESCRIPTION OF THE ATTACHED DOCUMENT 

Application for Pro Hav Vice Admission 

(Title or description of attached document) 

(Title or description of attached document continued) 

Number of Pages __ Document Date, ___ _ 

Additional information 

2015 Version www.NotaryCiasses.com 800-873-9865 

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 

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 

was previously signed, it must be re-signed in front of the notary public during the jurat 

process. 

State and county information must be the state and county where the 

document signer(s) personally appeared before the notary public. 

Date of notarization must be the date the signer(s) personally 

appeared which must also be the same date the jurat process is 

completed. 

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 

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. 

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 ex as 

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 

1 

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· S 1~-.:f..l-'i\Of'l Wut>"ito:o "'"""' '11e nn(~ 1X \•g J05 Wdl t4~h Sire~;~, Slit f!Qpr 

Aus~in, Tt:X!l:> 78701 i 

I 

Austin, Texas 78711·3486