On January 09, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Cornerstone Capital Bank Ssb,
Cornerstone Home Lending Inc,
Cornerstone Home Lending,
Valdes, Manuel,
and
Laird, Adam,
Laird, Marc,
Valdes, Manuel,
for SWORN ACCOUNT
in the District Court of Harris County.
Preview
CAUSE NO. 2023 01256
CORNERSTONE CAPITAL BANK, SSB, IN THE DISTRICT COURT
Plaintiff,
11th JUDICIAL DISTRICT
MANUEL VALDES,
Counter Plaintiff/Third HARRIS COUNTY, TEXAS
Plaintiff
MARC LAIRD LAIRD,
ELI WATKINS MOTION APPEAR VICE
At the request of his client, Manuel Valdes, and pursuant to Rule 19(a) of the Rules
Governing Admission to the Bar of Texas, Eli Watkins moves this Court for an rder allowing
to appear before this Court pro hac vice for the particular purpose of serving as co counsel in
this action. In support of this motion, the movant shows the following:
Throughout the course of this ac Eli Watkins will be associated with the
following Texas counsel:
Brandi J. Mc
State Bar No. 24075380
brandi@brownfoxlaw.com
State Bar No. 24036471
david@brownfoxlaw.com
Morgan M. Buller
State Bar No. 24109670
morgan@brownfoxlaw.com
6303 Cowboys Way, Suite 400
Frisco, Texas 75034
(972) 707 1860 (Telephone)
OTION APPEAR PRO VICE AGE
(214) 327-5001 (Facsimile)
2. Eli Watkins is a fellow with the law firm Sanford Heisler Sharp, LLP and may be
contacted as follows:
Address: 17 State Street, 37th Floor, New York, NY 10004
Telephone: (646) 402-5647
Fax: (646) 402-5651
E-mail address: ewatkins@sanfordheisler.com
3. Eli Watkins is licensed to practice in all courts in the State of New York and before
the U.S. District Court for the Southern District of New York.
4. Eli Watkins, whose New York Bar No. is 6029847, is an active member in good
standing of the State Bar of New York and the federal court listed above.
5. Eli Watkins has not been the subject of any disciplinary action by the bar or courts
of any jurisdiction in which he has been licensed to practice and has not been denied admission to
any state or federal court in the preceding five (5) years.
6. Eli Watkins has not appeared pro hac vice or sought leave to appear or participate
in any case or cause in Texas courts within the past two years.1
7. Eli Watkins is familiar with the Texas 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 and, as evidenced by his signature below, agrees to at all times abide by and comply
with such rules throughout his representation in this action.
8. Proof of payment of the required fee to the Texas Board of Law Examiners pursuant
to Section 82.0361 of the Texas Government Code is attached hereto as Exhibit A.
1
Eli Watkins was granted admittance pro hac vice in Cornerstone Capital Bank, SSB v. Valdes, Case No. 4:23-cv-
03685 (S.D. Tex.).
ELI WATKINS’S MOTION TO APPEAR PRO HAC VICE PAGE 2
PRAYER
For these reasons, Eli Watkins respectfully requests that this Court grant Motion
Hac Vice and allow Watkins to appear before this Court on behalf of Defendant
Plaintiff/Third Party Plaintiff Manuel Valdes
Respectfully submitted,
th Day of March, 2024
Respectfully submitted,
/s/ Eli Watkins
Eli Watkins ( vice to be submitted
SANFORD HEISLER SHARP, LLP
17 State Street, 37th Floor
New York, New York 10004
Telephone: (646) 402 5650
Facsimile: (646) 402 5651
ewatkins@sanfordheisler.com
SANFORD HEISLER SHARP, LLP
David Tracey (
pro hac vice
Jeremy Heisler (pro hac vice
pro hac vice
17 State Street, 37 Floor
New York, New York 10004
Telephone: (646) 402 5650
Facsimile: (646) 5651
dtracey@sanfordheisler.com
dsanford@sanfordheisler.com
jheisler@sanfordheisler.com
amelzer@sanfordheisler.com
ewatkins@sanfordheisler.com
Danielle Fuschetti (pro hac vice
300 Hamilton Avenue, Suite 500
Palo Alto, CA 94301
OTION APPEAR PRO VICE AGE
dfuschetti@sanfordheisler.com
Telephone: (650) 272 3366
Facsimile: (646) 402 5651
pro hac vice
Michael Lockman (pro hac vice
David McNamee (pro hac vice
Kasi Wautlet (pro hac vice
611 Commerce Street, Suite 3100
Nashville, TN 37203
bhannafan@sanfordheisler.com
mlockman@sanfordheisler.com
dmcnamee@sanforheisler.com
kwautlet@sanfordheisler.com
Telephone: (615) 434 7000
Facsimile: (615) 434 7020
BROWN FOX PLLC
Brandi J. McKay
State Bar No. 24075380
brandi@brownfoxlaw.com
State Bar No. 24036471
david@brownfoxlaw.com
Morgan M. Buller
State Bar No. 24109670
morgan@brownfoxlaw.com
owboys Way, Suite 400
Frisco, Texas 75034
(972) 707 1860 (Telephone)
(214) 327 5001 (Facsimile)
ATTORNEYS FOR DEFENDANT/COUNTER
PLAINTIFF/THIRD PARTY PLAINTIFF
MANUEL VALDES
OTION APPEAR PRO VICE AGE
CERTIFICATE OF CONFERENCE
This is to certify that the undersigned counsel has conferred with counsel for
Plaintiff/Counter Defendant Cornerstone Capital Bank, SSB and Third Party Defendants Marc
Laird and Adam Laird on March , 2024, regarding Eli Watkins’s Motion To Appear Pro Hac
in the above styled cause of action as co counsel for Defendant/Counter Plaintiff/Third
Plaintiff Manuel Valdes. has indicated that it is unopposed to the motion
RACEY
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing has been
forwarded in accordance with the Texas Rules of Civil Procedure to all counsel of record via the
electronic filing system on the th Day of March, 2024
RACEY
OTION APPEAR PRO VICE AGE
My name is Eli Watkins. My date of birth is April 10, 1993. My business address 17
State Street, 37th Floor, New York, NY 10004 I declare under penalty of perjury that the
statements contained in the foregoing Motion are within my personal knowledge and are true and
correct.
/s/ Eli Watkins
ATKINS
Executed in New York County, New York
March
OTION APPEAR PRO VICE AGE
Preview
CAUSE NO. 2023 01256 CORNERSTONE CAPITAL BANK, SSB, IN THE DISTRICT COURT Plaintiff, 11th JUDICIAL DISTRICT MANUEL VALDES, Counter Plaintiff/Third HARRIS COUNTY, TEXAS Plaintiff MARC LAIRD LAIRD, ELI WATKINS MOTION APPEAR VICE At the request of his client, Manuel Valdes, and pursuant to Rule 19(a) of the Rules Governing Admission to the Bar of Texas, Eli Watkins moves this Court for an rder allowing to appear before this Court pro hac vice for the particular purpose of serving as co counsel in this action. In support of this motion, the movant shows the following: Throughout the course of this ac Eli Watkins will be associated with the following Texas counsel: Brandi J. Mc State Bar No. 24075380 brandi@brownfoxlaw.com State Bar No. 24036471 david@brownfoxlaw.com Morgan M. Buller State Bar No. 24109670 morgan@brownfoxlaw.com 6303 Cowboys Way, Suite 400 Frisco, Texas 75034 (972) 707 1860 (Telephone) OTION APPEAR PRO VICE AGE (214) 327-5001 (Facsimile) 2. Eli Watkins is a fellow with the law firm Sanford Heisler Sharp, LLP and may be contacted as follows: Address: 17 State Street, 37th Floor, New York, NY 10004 Telephone: (646) 402-5647 Fax: (646) 402-5651 E-mail address: ewatkins@sanfordheisler.com 3. Eli Watkins is licensed to practice in all courts in the State of New York and before the U.S. District Court for the Southern District of New York. 4. Eli Watkins, whose New York Bar No. is 6029847, is an active member in good standing of the State Bar of New York and the federal court listed above. 5. Eli Watkins has not been the subject of any disciplinary action by the bar or courts of any jurisdiction in which he has been licensed to practice and has not been denied admission to any state or federal court in the preceding five (5) years. 6. Eli Watkins has not appeared pro hac vice or sought leave to appear or participate in any case or cause in Texas courts within the past two years.1 7. Eli Watkins is familiar with the Texas 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 and, as evidenced by his signature below, agrees to at all times abide by and comply with such rules throughout his representation in this action. 8. Proof of payment of the required fee to the Texas Board of Law Examiners pursuant to Section 82.0361 of the Texas Government Code is attached hereto as Exhibit A. 1 Eli Watkins was granted admittance pro hac vice in Cornerstone Capital Bank, SSB v. Valdes, Case No. 4:23-cv- 03685 (S.D. Tex.). ELI WATKINS’S MOTION TO APPEAR PRO HAC VICE PAGE 2 PRAYER For these reasons, Eli Watkins respectfully requests that this Court grant Motion Hac Vice and allow Watkins to appear before this Court on behalf of Defendant Plaintiff/Third Party Plaintiff Manuel Valdes Respectfully submitted, th Day of March, 2024 Respectfully submitted, /s/ Eli Watkins Eli Watkins ( vice to be submitted SANFORD HEISLER SHARP, LLP 17 State Street, 37th Floor New York, New York 10004 Telephone: (646) 402 5650 Facsimile: (646) 402 5651 ewatkins@sanfordheisler.com SANFORD HEISLER SHARP, LLP David Tracey ( pro hac vice Jeremy Heisler (pro hac vice pro hac vice 17 State Street, 37 Floor New York, New York 10004 Telephone: (646) 402 5650 Facsimile: (646) 5651 dtracey@sanfordheisler.com dsanford@sanfordheisler.com jheisler@sanfordheisler.com amelzer@sanfordheisler.com ewatkins@sanfordheisler.com Danielle Fuschetti (pro hac vice 300 Hamilton Avenue, Suite 500 Palo Alto, CA 94301 OTION APPEAR PRO VICE AGE dfuschetti@sanfordheisler.com Telephone: (650) 272 3366 Facsimile: (646) 402 5651 pro hac vice Michael Lockman (pro hac vice David McNamee (pro hac vice Kasi Wautlet (pro hac vice 611 Commerce Street, Suite 3100 Nashville, TN 37203 bhannafan@sanfordheisler.com mlockman@sanfordheisler.com dmcnamee@sanforheisler.com kwautlet@sanfordheisler.com Telephone: (615) 434 7000 Facsimile: (615) 434 7020 BROWN FOX PLLC Brandi J. McKay State Bar No. 24075380 brandi@brownfoxlaw.com State Bar No. 24036471 david@brownfoxlaw.com Morgan M. Buller State Bar No. 24109670 morgan@brownfoxlaw.com owboys Way, Suite 400 Frisco, Texas 75034 (972) 707 1860 (Telephone) (214) 327 5001 (Facsimile) ATTORNEYS FOR DEFENDANT/COUNTER PLAINTIFF/THIRD PARTY PLAINTIFF MANUEL VALDES OTION APPEAR PRO VICE AGE CERTIFICATE OF CONFERENCE This is to certify that the undersigned counsel has conferred with counsel for Plaintiff/Counter Defendant Cornerstone Capital Bank, SSB and Third Party Defendants Marc Laird and Adam Laird on March , 2024, regarding Eli Watkins’s Motion To Appear Pro Hac in the above styled cause of action as co counsel for Defendant/Counter Plaintiff/Third Plaintiff Manuel Valdes. has indicated that it is unopposed to the motion RACEY CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing has been forwarded in accordance with the Texas Rules of Civil Procedure to all counsel of record via the electronic filing system on the th Day of March, 2024 RACEY OTION APPEAR PRO VICE AGE My name is Eli Watkins. My date of birth is April 10, 1993. My business address 17 State Street, 37th Floor, New York, NY 10004 I declare under penalty of perjury that the statements contained in the foregoing Motion are within my personal knowledge and are true and correct. /s/ Eli Watkins ATKINS Executed in New York County, New York March OTION APPEAR PRO VICE AGE