Pro Hac Vice admission - Updated to add complaints
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I was doing something research and came across the term Pro Hac Vice admission. I found this really interesting, since Exegy has many attorneys working on the case against me from behind the scenes, but only one attorney is stated on court documents.
I am going to have to research this further, but here what Google Gemini has stated to me. The below is a copy of what Gemini stated, but there more and need to correct the formatting, so check out the link.
https://gemini.google.com/share/cc8665060398
I am currently working on my complaints for the Missouri bar against all the attorney I can prove at working on this case behind the scenes., sorry Tina Babel but another complaint is coming your way for assisting with practicing law illegally in Missouri.
Complaint Summary on each attorney (Patrick Sellers, Robert Earles & Tina Babel)
Complaint attachments can be found at the following share
https://drive.google.com/drive/folders/1URY1nFba0m2Hf2m_qosbPqB6xzYHteVX
Complaint 1: Tina Babel (Missouri Counsel of Record)
Relevant Rules: Rule 4-3.3 (Candor Toward the Tribunal), Rule 4-5.5(b) (Assisting Unauthorized Practice of Law).
Statement of Facts:
"I am the defendant in Exegy Inc. v. Walters (25SL-CC09400). Ms. Babel is the attorney of record for the Plaintiff. On August 20, 2025, at 12:18 PM, I sent an email to Ms. Babel explicitly stating that I was blocking all emails from her until I secured legal representation (see attached). Despite this direct notice, Ms. Babel represented to the Court that I had been served with a Temporary Restraining Order (TRO) via email. Because I had effectively severed the communication channel to prevent contact while seeking counsel, her representation to the court that I was served was factually impossible and misleading.
Furthermore, Ms. Babel is knowingly working with out-of-state attorneys Patrick Sellers and Robert Earles. Emails from April and August 2025 show these individuals are directing the litigation for this Missouri case. Ms. Babel is aware they are not admitted pro hac vice or registered in Missouri, yet she continues to facilitate their unauthorized practice of law."
Complaint 2: Patrick Sellers (Missouri Counsel of Record)
Relevant Rules: Rule 8.105 (Limited Admission for In-House Counsel), Rule 4-5.5 (Unauthorized Practice of Law), Rule 4-8.4 (Misconduct/Dishonesty).
Statement of Facts:
"Mr. Sellers is the General Counsel for Exegy. In an email dated February 9, 2025, he confirmed he is licensed in CA, NY, and IL, but not Missouri. Although he has a New York license, he has failed to obtain the mandatory 'Limited Admission' registration required by Missouri Rule 8.105 to practice as in-house counsel in this state.
Mr. Sellers appears to be providing conflicting information regarding his location to evade registration requirements. In an email dated April 25, 2025, he directed legal mail to be sent to Exegy’s St. Louis HQ 'ATTN: Legal Department.' However, he has concurrently informed the Illinois ARDC (Ref: 2025IN01739) that he works out of a Chicago office—an office that disappeared from Exegy’s website in November 2024. Furthermore, I have an active grievance against Mr. Sellers for extortionate tactics. By managing a Missouri case and directing litigation from an unregistered status, while providing inconsistent information regarding his office location, he is violating Missouri's rules of professional conduct."
I have also attached a letter sent by Mr. Sellers that contains only the Exegy Headquarters address in Missouri and a screenshot of his LinkedIn profile showing he has been working with Exegy Inc since June 2024.
Complaint 3: Robert (Bobby) Earles (Cooley LLP)
Relevant Rules: Rule 4-5.5 (Unauthorized Practice of Law), Rule 9.03 (Visiting Attorneys).
Statement of Facts:
"Mr. Earles is an attorney with Cooley LLP, based in Illinois. On August 11, 2025, Patrick Sellers (Exegy GC) sent an email designating Mr. Earles as the primary attorney representing Exegy in the Missouri matter (25SL-CC09400) and directed all legal communications to him.
Mr. Earles is not licensed in Missouri and has not filed for pro hac vice admission in Case No. 25SL-CC09400 as required by Rule 9.03. By acting as the lead designated counsel in a Missouri civil action and directing legal correspondence without court authorization or a Missouri license, Mr. Earles is engaged in the unauthorized practice of law."
Google Gemini Response
Yes, if an out-of-state attorney is actively working on a case in Missouri, they generally must be added to the court record through a process called Pro Hac Vice admission.
In Missouri, a corporation cannot represent itself and must be represented by a licensed attorney. If that attorney is from another state, they cannot simply "work behind the scenes" while the in-state attorney handles the filings; they must be formally recognized by the court to practice law for that specific case.
Why All Counsel Must Be Added
Under Missouri Supreme Court Rule 9.03, any attorney not licensed in Missouri who wishes to represent a client in a Missouri court must follow these steps:
Associate with Local Counsel: The out-of-state lawyer must partner with an attorney who is a member in good standing of the Missouri Bar and who resides in Missouri.
File a Motion for Admission: The Missouri attorney (local counsel) must file a motion asking the court to admit the out-of-state attorney pro hac vice (meaning "for this occasion only").
Pay a Fee: The out-of-state attorney must pay a fee to the Clerk of the Supreme Court of Missouri (currently $410 per case) and provide a statement of good standing from their home state.
The Role of Each Attorney
Once admitted, both attorneys have specific responsibilities on the case record:
Attorney Type | Role in the Case | Requirement |
In-State (Local) Counsel | Serves as the primary point of contact for the court and ensures compliance with local rules. | Must sign all pleadings and usually must appear at all hearings unless excused. |
Out-of-State Counsel | Provides specialized expertise or maintains a pre-existing relationship with the company. | Must be admitted pro hac vice to sign documents, argue in court, or take depositions. |
What happens if they aren't added?
If an out-of-state attorney performs legal work (like signing a motion or conducting a deposition) without being added to the case:
Unauthorized Practice of Law: The attorney could be sanctioned for practicing law in a state where they are not licensed.
Invalid Filings: The court may strike (ignore) any documents signed by an attorney who has not been formally admitted to the case.
Ethical Violations: Both the out-of-state and the in-state attorney could face disciplinary action from the Missouri Bar.
Exceptions
There is a small exception for In-House Counsel. Under Rule 8.105, an out-of-state attorney who is a full-time employee of the corporation can sometimes obtain a "Limited Admission" to provide legal services solely for that employer without being admitted for every single case, though they still often associate with local counsel for specific litigation
Updated on 3/20/2025 @ 13:32 CST
● Added Complaints filed with the Missouri Bar
● Added Complaints attachments
