Texas State Board of Social Worker Examiners v. Katherin Youniacutt and Tammy Thompson
Opinion
ACCEPTED
15-25-00064-CV
FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS
5/9/2025 1:37 PM
No. 15-25-00064-CV CHRISTOPHER A. PRINE CLERK
IN THE FIFTEENTH COURT OF APPEALS FILED IN 15th COURT OF APPEALS
AUSTIN, TEXAS
5/9/2025 1:37:18 PM
CHRISTOPHER A. PRINE
TEXAS STATE BOARD OF SOCIAL WORKER EXAMINERS, ET AL, Clerk
Appellants,
v.
KATHERIN YOUNIACUTT AND TAMMY THOMPSON, Appellees.
Appeal from the 345th Judicial District Court of Travis County, Texas Trial Case No. D-1-GN-24-009236
UNOPPOSED VERIFIED MOTION OF JAMES T. KNIGHT II FOR ADMISSION PRO HAC VICE
TO THE HONORABLE JUDGE OF SAID COURT:
Pursuant to Rule XIX of the Rules Governing Admission to the Bar of Texas, I, James T. Knight II, file this Unopposed Verified Motion for Admission Pro Hac Vice and respectfully state as follows:
1. I am an attorney with the Institute for Justice in Arlington, Virginia at 901 N. Glebe Road, Suite 900, Arlington, Virginia 22203; telephone (703) 682-9320; facsimile (703) 682-9321; email jknight@ij.org.
2. I am associated with counsel for Appellants. Arif Panju is a managing attorney with the Institute for Justice in Texas at 816 Congress Avenue, Suite 970, Austin, Texas 78701-2475; telephone (512) 480-5936; facsimile (512) 480-5937; email apanju@ij.org. Mr. Panju is a member in good standing of the State Bar of Texas (TX Bar No. 24070380).
3. I have appeared or have sought leave to appear or participate in the past two years in the following cases and causes in Texas courts: Cause Number Caption
2019-39625 The State of Texas v. Approximately $41,680.00, 281st District Court of Harris County (admission pro hac vice granted on April 21, 2022).
01-23-00818-CV Ameal Woods and Jordan Davis v. The State of Texas, Court of Appeals for the First District of Texas at Houston (admission pro hac vice granted on January 18, 2024).
01-23-00863-CV Ameal Woods and Jordan Davis v. Harris County, et al., Court of Appeals for the First District of Texas at Houston (admission pro hac vice granted on January 25, 2024).
D-1-GN-24-009236 Katherin Youniacutt and Tammy Thompson v. Texas State Board of Social Worker Examiners, et al., 345th Judicial District Court of Travis County, Texas (admission pro hac vice granted on February 5, 2025).
4. I am an attorney currently licensed, in good standing, and admitted to practice in the District of Columbia (Bar No. 1671382; admitted December 29, 2019). I am also in good standing and admitted to practice in the United States District Court for the District of Colorado (March 2021), the United States District Court for the Central District of Illinois (March 2024), and the United States Court of Appeals for the Fourth Circuit (April 2023). No disciplinary action or investigation of my conduct is pending.
5. I have never been subjected to discipline in any jurisdiction and there are presently no disciplinary proceedings pending against me in any jurisdiction. 6. I have never been denied admission to the courts of this or any other state or to any federal court. 7. I am familiar with the 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. I will at all times abide by and comply with the same so long as this cause of action is pending. 8. Pursuant to Rule XIX(c) of the Rules Governing Admission to the Bar of Texas, attached hereto is the proof of payment from the Board of Law Examiners. 9. Pursuant to Rule XIX(b) of the Rules Governing Admission to the Bar of Texas, the motion of the resident practicing Texas attorney with whom Movant will be associated in the proceeding of this cause accompanies this motion. The motion of the resident attorney states that the resident attorney finds the Movant to be a reputable attorney and recommends that Movant be granted permission to participate in this proceeding before the Court.
WHEREFORE, I respectfully request that this Court permit me to appear before the Court until the conclusion of this case.
Dated: May 9, 2025. Respectfully submitted,
/s/ Arif Panju /s/ James T. Knight II Arif Panju (TX Bar No. 24070380) James T. Knight II (D.C. Bar No. 1671382)* Institute for Justice Institute for Justice 816 Congress Avenue, Suite 970 901 N. Glebe Rd., Suite 900 Austin, TX 78701 Arlington, VA 22203 Tel.: (512) 480-5936 Tel.: (703) 682-9320 apanju@ij.org Fax: (703) 682-9321 jknight@ij.org
Attorney for Appellees *Pro Hac Vice Admission Pending
VERIFICATION
COMMONWEALTH OF VIRGINIA § §
COUNTY OF ARLINGTON §
BEFORE ME, the undersigned authority, on this day personally appeared JAMES T. KNIGHT II, known to me to be the person whose name is subscribed below and after having been duly sworn, on his oath stated that the facts set forth in paragraphs 1-8 of the foregoing Unopposed Motion for Admission Pro Hae Vice are within his personal knowledge and are true and correct.
6rneiT. Knight II
SUBSCRIBED AND SWORN TO before me on this 8""'°' day of M~ , 2025.
Claire Elizabeth Purple
NOTARY PUBLIC
REGISTRATION # 7768934
COMMONWEALTH OF VIRGINIA
MY COMMISSION EXPIRES May 31 , 202.13
Notary Public-Commonwealth of Virginia My Commission Expires: ~ '3 I , cilOa. Lt
CERTIFICATE OF SERVICE
I hereby certify that on May 9, 2025, a true and correct copy of the foregoing motion was filed with the Clerk of Court and served in compliance with the Texas Rules of Appellate Procedure via the Court’s electronic filing system on the following counsel of record:
Beth Klusmann Office of the Attorney General P.O. Box 12548 (MC 059) Austin, Texas 78711-2548 Tel.: (512) 936-1914 Fax: (512) 474-2697 Beth.Klusmann@oag.texas.gov
Counsel for Appellants
/s/ Arif Panju___________ Arif Panju
CERTIFICATE OF CONFERENCE As required by Texas Rules of Appellate Procedure 10.1(a)(5), I certify to the Court that I conferred with opposing counsel on May 9, 2025 about the merits of this motion and opposing counsel has indicated that she does not oppose the motion.
/s/ Arif Panju___________ Arif Panju
Board of Law Examiners
Appointed by the Supreme Court of Texas
May 07, 2025
James T. Knight II Via: E-Mail
Acknowledgment Letter
Non-Resident Attorney Fee
According to Texas Government Code §82.0361, "a nonresident attorney requesting permission to participate in proceedings in a court in this state shall pay a fee of $250 for each case in which the attorney is requesting to participate."
This Acknowledgement Letter serves as proof that the Board of Law Examiners has received $250 in connection with the following matter:
Non-resident attorney: James T. Knight II Case: 15-25-00064-CV
Texas court or body: In the Court of Appeals for the Fifteenth Judicial District
After satisfying the fee requirement, a non-resident attorney shall file a motion in the Texas court or body in which the non-resident attorney is requesting permission to appear. The motion shall contain the information and statements required by Rule 19(a) of the Rules Governing Admission to the Bar of Texas. The motion must be accompanied by this Acknowledgment Letter and by a motion from a resident practicing Texas attorney that contains the statements required by Rule 19(b). The decision to grant or deny a non-resident attorney's motion for permission to participate in the proceedings in a particular cause is made by the Texas court or body in which it is filed. For more information, please see Rule 19 of the Rules Governing Admission to the Bar of Texas and §82.0361, of the Texas Government Code, which can be found on the Board's website.
Cordially,
Nahdiah Hoang
Exccuti vc Director
MAILING ADDRESS TELEPHONE: 512- 463-1621 - FACSIMILE: 512- 463-5300 STREET ADDRESS Post Office Box 13486 WEBSITE: www.ble.texas.gov 205 West 14th Street, Ste.500 Austin,Texas 78711-3486 Austin, Texas 78701
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Texas State Board of Social Worker Examiners v. Katherin Youniacutt and Tammy Thompson (Texas State Board of Social Worker Examiners v. Katherin Youniacutt and Tammy Thompson) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.