In Re TikTok Inc.; TikTok Ltd.; TikTok Pte. Ltd.; TikTok U.S. Data Security Inc.; ByteDance Ltd.; And ByteDance Inc. v. the State of Texas

ACCEPTED
15-25-00209-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
12/4/2025 2:16 PM
CHRISTOPHER A. PRINE
No. 15-25-00209-CV CLERK
FILED IN
IN THE COURT OF APPEALS 15th COURT OF APPEALS
AUSTIN, TEXAS
FOR THE FIFTEENTH DISTRICT OF TEXAS 12/4/2025
AT 2:16:28 PM
CHRISTOPHER A. PRINE
Clerk
AUSTIN

I N RE T IK T OK I NC ., T IK T OK L TD.; T IKTOK P TE .;
T IK T OK U.S. D ATA S ECURITY I NC .;
B YTE D ANCE L TD .; AND B YTE D ANCE , I NC .,
RELATORS.

On Petition for Writ of Mandamus from the
250th Judicial District Court of Travis County, Texas
Trial Court Cause No. D-1-GN-25-003118
Honorable Cory Liu, Presiding Judge

MOTION FOR ADMISSION PRO HAC VICE
OF JOHN D. OHLENDORF

Pursuant to Rule 19(b) of the Texas Supreme Court Rules Governing Admission

to the Bar of Texas, State of Texas, real-party in interest in this proceeding and Plaintiff

in the court below, by counsel, hereby respectfully moves for the admission of John D.

Ohlendorf, pro hac vice. As grounds therefore, the State shows the following:

1. John D. Ohlendorf is a partner at Cooper & Kirk, PLLC:

1523 New Hampshire Avenue, N.W.
Washington, DC 20036
Telephone: (202) 220-9600
Facsimile: (202) 220-9601
johlendorf@cooperkirk.com

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2. Mr. Ohlendorf will be associated with Richard McCutcheon from the Office

of the Attorney General of Texas. Mr. McCutcheon is a practicing attorney

and member in good standing with the State Bar of Texas. His state bar

number and contact information is as follows:

Texas Bar No. 24139547
808 Travis Street, Suite 1520
Houston, Texas 77002
Telephone: (713) 225-8926
Facsimile: (713) 223-5821
Richard.McCutcheon@oag.texas.gov

3. Mr. Ohlendorf filed a motion for permission to appear pro hac vice in the 250th

Judicial District Court of Travis County on December 4, 2025, in Cause No.

D-1-GN-25-003118. The Court has not ruled on the motion.

4. Mr. Ohlendorf is admitted to practice and is in good standing before the State

bars of District of Columbia and Missouri, and the following federal courts:

the United States District Courts for the District of Columbia, District of

Colorado, and Eastern District of Missouri; the United States Courts of

Appeals for the First, Second, Third, Fourth, Fifth, Sixth, Seventh, Ninth,

Tenth, Eleventh, Federal, and D.C. Circuits; the United States Court of

Federal Claims; and the United States Supreme Court.

5. Mr. Ohlendorf has not been the subject of disciplinary action by the Bar or

courts of any jurisdiction in which he is licensed within the past five years.

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6. Mr. Ohlendorf has not been denied admission to the courts of any State or

to any federal court in the past five years.

7. Mr. Ohlendorf is 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 Bar, and will at all times abide by and comply with the same

so long as such Texas proceeding is pending and he has not withdrawn as

counsel therein.

PRAYER

For these reasons, the State asks this Court to grant this Motion for Pro Hac

Vice Admission and allow John D. Ohlendorf to appear before this Court in this

proceeding until the conclusion of this case.

Dated: December 4, 2025 Respectfully submitted,

/s/ John D. Ohlendorf__
John D. Ohlendorf
COOPER & KIRK, PLLC
1523 New Hampshire Ave., N.W.
Washington, D.C., 20036
Telephone: (202) 220-9600
Facsimile: (202) 220-9601
johlendorf@cooperkirk.com

ATTORNEY FOR REAL PARTY IN
INTEREST STATE OF TEXAS

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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing instrument was
forwarded to all counsel of record by electronic filing in accordance with the Texas
Rules of Appellate Procedure on December 4, 2025

/s/ John D. Ohlendorf
John D. Ohlendorf

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EXHIBIT 1
Board of Law Examiners
Appointed by the Supreme Court of Texas

December 02, 2025

Harrison Wells
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: John D. Ohlendorf
Case: 15-25-00209-CV
Texas court or body: Court of Appeals For the Fifteenth District of Texas at Austin

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.

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
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.

Envelope ID: 108726035
Filing Code Description: Motion
Filing Description: MOTION FOR ADMISSION PRO HAC VICE OF JOHN
D. OHLENDORF
Status as of 12/4/2025 3:32 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Brandon Duke bduke@omm.com 12/4/2025 2:16:28 PM SENT

Trial Court 250.submission@traviscountytx.gov 12/4/2025 2:16:28 PM SENT

Adam Holtz adam.holtz@oag.texas.gov 12/4/2025 2:16:28 PM SENT

Brian Barnes bbarnes@cooperkirk.com 12/4/2025 2:16:28 PM SENT

David Thompson dthompson@cooperkirk.com 12/4/2025 2:16:28 PM SENT

Adam Laxalt alaxalt@cooperkirk.com 12/4/2025 2:16:28 PM SENT

Madeline Fogel madeline.fogel@oag.texas.gov 12/4/2025 2:16:28 PM SENT

Hannah Campus hannah.campus@oag.texas.gov 12/4/2025 2:16:28 PM SENT

Melinda Pate melinda.pate@oag.texas.gov 12/4/2025 2:16:28 PM SENT

Jerry Bergman jerry.bergman@oag.texas.gov 12/4/2025 2:16:28 PM SENT

Calendar Litigation litigationcalendar@omm.com 12/4/2025 2:16:28 PM SENT

Megan Crowley mcrowley@cov.com 12/4/2025 2:16:28 PM SENT

Richard Mccutcheon richard.mccutcheon@oag.texas.gov 12/4/2025 2:16:28 PM SENT

Zoann Willis zoann.willis@oag.texas.gov 12/4/2025 2:16:28 PM SENT

Rebecca Hermann rebecca.herrmann@oag.texas.gov 12/4/2025 2:16:28 PM SENT