City of Kountze Mesothelioma and Toxic Exposure Attorneys: Holding Corporations Accountable for Southeast Texas Workers

For decades, the men and women of the City of Kountze have fueled the American economy, driving down U.S. Highway 69 every morning to the massive refineries and shipyards that define the Southeast Texas landscape. You worked the long shifts at the ExxonMobil Beaumont refinery, handled the specialized maintenance at the Goodyear chemical plant, and stripped the outdated lagging at the shipyards along the Neches River. You did the hard work that built this country, trusting that the corporations you served were protecting your health. But while you were providing for your family in the City of Kountze, those same billion-dollar companies were sitting on internal memos and medical studies proving that the dust you breathed and the chemicals you touched were lethal.

At Attorney 911, we believe that a diagnosis of mesothelioma, acute myeloid leukemia (AML), or a catastrophic industrial injury is not just a medical crisis—it is a betrayal of the highest order. We are not a settlement mill, and we are not a referral service that passes your case to another firm. Led by Ralph Manginello, an attorney with 27-plus years of experience who was part of the massive litigation team in the $2.1 billion BP Texas City refinery explosion case, we understand the specific industrial landscape of the City of Kountze and Hardin County. We are backed by Lupe Peña, a former insurance defense attorney who spent years inside the machine, learning exactly how corporate legal teams suppress evidence and minimize worker claims. We don’t just know the law; we know the enemy’s playbook, and we are here to help victims in the City of Kountze fight back.

If you or a loved one has been diagnosed with an asbestos-related disease or a chemical-induced cancer after working in Southeast Texas industries, the clock is already running. The evidence that proves your exposure is being destroyed with every plant decommissioning, and trust fund assets are depleting every year. Do not wait for the corporations to offer a fair settlement—they never will. Call 1-888-ATTY-911 today for a free, confidential case evaluation.

The Southeast Texas Industrial Betrayal: Why City of Kountze Workers Are at Risk

The City of Kountze sits in the heart of one of the most toxic industrial corridors in the world. While our community is known for its proximity to the Big Thicket and its quieter pace of life, the economic lifeblood of the City of Kountze has always been tied to the “Golden Triangle” petrochemical hub. This region—comprised of Beaumont, Port Arthur, and Orange—houses the highest concentration of oil refineries and chemical plants in the United States. For a worker in the City of Kountze, a career at these facilities was a point of pride, but the “Golden Triangle” has a darker side: it is also ground zero for some of the highest rates of mesothelioma and industrial cancers in the nation.

Workers who commuted from the City of Kountze to the ExxonMobil Beaumont refinery or the Motiva Port Arthur complex were exposed daily to a cocktail of carcinogens. Asbestos was used for decades as insulation on every process pipe, heat exchanger, and boiler in those facilities. Benzene was a constant byproduct of the refining process, invisible and odorless but toxic to the bone marrow of City of Kountze refinery operators. Even today, as you spend your retirement in the City of Kountze, the microscopic fibers and chemical mutations caused by exposures in the 1970s, 80s, and 90s may be silently developing into life-threatening diseases. At Attorney 911, we understand the Southeast Texas industrial history because we have spent more than two decades in the courtrooms of Jefferson, Hardin, and Harris Counties holding these companies accountable.

The corporate defense teams count on you not knowing the difference between a workers’ compensation claim and a third-party toxic tort lawsuit. They want you to believe that the small checks you might receive from insurance are your only option. They are wrong. If your employer or a product manufacturer knowingly exposed you to toxins, you may be entitled to millions in compensation from bankruptcy trust funds and civil juries. From our principal office in Houston and our active practice across Southeast Texas, we bring the fight to the corporations that poisoned our neighbors in the City of Kountze.

The Anchor Case: Mesothelioma and the Science of Asbestos Exposure

Mesothelioma is a devastating cancer that is caused almost exclusively by exposure to asbestos fibers. In the City of Kountze, many residents worked in trades—insulators, pipefitters, boilermakers, and electricians—where asbestos was a daily reality. This disease is unique because of its long latency period; a City of Kountze worker exposed in 1975 might not show symptoms until 2026. This 15-to-50-year gap is not because the asbestos is slow-acting, but because of the specific biological mechanism by which these fibers destroy the human body.

The Cellular Mechanism: How Asbestos Kills

Asbestos is not a single chemical, but a group of six naturally occurring silicate minerals that form microscopic, needle-like fibers. When a worker at a refinery near the City of Kountze cut through a section of Kaylo pipe insulation or handled a Pittsburgh Corning Unibestos block, millions of these fibers were released into the air. These fibers are so small they bypass the body’s natural filters in the nose and throat, traveling deep into the lungs.

The core of the disease is a process called “frustrated phagocytosis.” Your body’s immune system sends specialized cells called macrophages to engulf and destroy foreign particles. However, asbestos fibers—particularly the sharp, needle-like amphibole fibers (amosite and crocidolite)—are too long and too rigid for the macrophages to consume. When the macrophage tries to wrap around the fiber, it ruptures. This cell death releases a cascade of inflammatory cytokines (TNF-α, IL-1β, IL-6) and reactive oxygen species (ROS) directly into the mesothelial tissue—the thin lining that covers your lungs (pleura) or abdomen (peritoneum).

This chronic inflammation lasts for decades because the fibers never dissolve. They are “biopersistent.” Over thousands of cell divisions, the constant barrage of reactive oxygen species damages the DNA of the mesothelial cells. Specifically, asbestos exposure is known to inactivate critical tumor suppressor genes, such as BAP1 and NF2 (merlin). When these genetic “brakes” are removed, the cells undergo malignant transformation. By the time a resident of the City of Kountze feels the first shortness of breath or persistent cough, the cancer has already established a complex tumor microenvironment that resists many standard treatments.

Recognizing the Symptoms in the City of Kountze

Because of the long latency period, many City of Kountze residents attribute early mesothelioma symptoms to aging or prior smoking habits. It is critical to understand that smoking does NOT cause mesothelioma, though it does multiply the risk of asbestos-related lung cancer. If you worked in Southeast Texas industry and are experiencing any of the following, you must tell your doctor about your asbestos history:

1. Pleural Mesothelioma (Lungs): A persistent dry cough, chest wall pain that worsens with deep breathing, progressive shortness of breath, and unexplained weight loss.
2. Peritoneal Mesothelioma (Abdomen): Abdominal swelling (ascites), severe abdominal pain, nausea, and changes in bowel habits.
3. General Signs: Night sweats, chronic fatigue, and a low-grade fever that won’t go away.

If you are diagnosed, you need the world-class care found at NCI-designated centers like MD Anderson Cancer Center in Houston, located less than two hours from the City of Kountze. Attorney Ralph Manginello can explain the importance of documenting your diagnosis for litigation in this video: https://www.youtube.com/watch?v=XwzYymneDVs. You can also listen to our podcast episode on the statute of limitations to ensure your window for filing isn’t closing: https://share.transistor.fm/s/bddc1426.

The Insider Advantage: Why Lupe Peña’s Background Matters for the City of Kountze

When you file a lawsuit against a company like ExxonMobil or Johns-Manville, you aren’t just fighting a corporation; you are fighting their insurance carriers and the Tier-1 defense firms they hire. These entities have spent 50 years developing a playbook designed to delay and deny claims from workers in places like the City of Kountze. They use “product defense” scientists to claim the science is inconclusive, and they exploit complicated corporate successor rules to hide their assets.

Our team at Attorney 911 includes Lupe Peña, a former insurance defense attorney who knows exactly how these companies operate. Lupe has seen the internal valuation spreadsheets. He knows how adjusters look for any “alternative cause”—like your history of smoking or even minor pre-existing conditions—to lower the value of your case. In the City of Kountze, where many workers have multi-decade histories across different plants, the defense will try to play a “shell game,” arguing that you can’t prove their specific product was the one that caused your cancer among the dozens you encountered.

Lupe Peña’s transition from the defense side to the plaintiff’s side is our firm’s nuclear advantage. As Greg Garcia noted in his verified Google review: “Big thank you for this law firm staff and Lupe Pena for taking good care of me. I highly recommend this law firm.” We use Lupe’s insider knowledge to anticipate the defense’s moves before they make them. While other firms are reacting to corporate tactics, we are already three steps ahead, subpoenaing the exact industrial hygiene reports and OSHA 300 logs that we know the insurance companies are trying to bury.

The insurance companies know that Ralph Manginello is a “PITT BULL” in the courtroom, as client Chad Harris described him. When you combine Ralph’s 27 years of trial experience with Lupe’s insider intelligence, you get a legal team that billion-dollar corporations actually fear. If you live in the City of Kountze and are tired of being treated like a claim number, call us at 1-888-ATTY-911 and speak with the team that knows the other side’s secrets.

Axis 1: Benzene and Chemical Exposure in Southeast Texas Refineries

While asbestos is the most famous toxic threat to City of Kountze workers, benzene is perhaps the most pervasive. Benzene is a natural component of crude oil and a fundamental building block of the petrochemical industry. If you worked at the Beaumont refinery or the Port Arthur chemical plants, you likely inhaled benzene vapors every day. High-risk jobs for City of Kountze residents included refinery operators, tank cleaners, laboratory technicians, and petroleum inspectors.

The Metabolism of Cancer: How Benzene Attacks the Bone Marrow

Benzene exposure is directly linked to Acute Myeloid Leukemia (AML), Myelodysplastic Syndrome (MDS), and Non-Hodgkin Lymphoma. Like asbestos, benzene’s damage is molecular. When you inhale benzene, your liver’s CYP2E1 enzymes metabolize it into highly reactive compounds, primarily benzene oxide and muconaldehyde. These metabolites don’t stay in the liver; they travel through the bloodstream and concentrate in the bone marrow—the factory where your body produces blood cells.

Once in the marrow, these chemicals cause “genotoxic stress.” They inhibit topoisomerase II, an enzyme essential for DNA repair, and cause specific chromosomal translocations. For workers who commuted from the City of Kountze to Southeast Texas plants, the clinical signature of benzene exposure is often found in specific DNA mutations, such as t(8;21) or del(5q). Over time, these mutations transform healthy stem cells into leukemic cells that crowd out healthy blood production.

Corporate Knowledge and the 1 ppm Failure

The current OSHA Permissible Exposure Limit (PEL) for benzene is 1 part per million (ppm). However, the industry knew that benzene caused leukemia as early as the 1940s. For decades, companies fought to keep the legal limit at 10 ppm, meaning City of Kountze workers were legally exposed to levels ten times higher than what modern science considers dangerous. Even at 1 ppm, there is no evidence of a “safe” threshold for leukemia risk.

If you worked with solvents, degreasers, or in the distillation units of a refinery and have been diagnosed with a blood cancer, you deserve more than a medical explanation. You deserve accountability. Juries have recently awarded landmark verdicts in benzene cases, including a $725 million award in 2024 against ExxonMobil for a mechanic who developed AML. https://www.osha.gov/benzene. Case results in this vertical are significant, but every case is unique; past results do not guarantee future outcomes. Contact Ralph Manginello for a free evaluation of your work history at 1-888-ATTY-911.

Axis 2: Dangerous Industries and the Rights of City of Kountze Workers

The City of Kountze isn’t just home to refinery workers; our community includes the tradespeople, truckers, and maritime workers who keep the Texas economy moving. When a catastrophic injury happens on the job, the employer’s first move is usually to steer you into the workers’ compensation system. They do this because workers’ comp caps your recovery and prevents you from suing for the full extent of your pain, suffering, and lost earning capacity.

The Construction Site Trap: Third-Party Liability in Hardin County

If you were injured in a scaffold fall, a crane collapse, or a trench cave-in at a construction site in or around the City of Kountze, workers’ comp is likely only the beginning of your recovery. Construction sites involve a complex web of general contractors, subcontractors, and equipment manufacturers. Under Texas law, if a party other than your direct employer was negligent, you can file a third-party personal injury claim.

These third-party claims are essential because they are not capped by the strict limits of the Texas Workers’ Compensation Act. They allow for the recovery of:

• Actual medical expenses (past and future)
• Full lost wages and lost earning capacity
• Physical impairment and disfigurement damages
• Mental anguish and pain and suffering

If a scaffold at a Beaumont high-rise project or a Southeast Texas plant expansion failed because it was improperly erected by a different subcontractor, that company is liable. Attorney Ralph Manginello explains the Houston and Southeast Texas guide to construction accidents in this video: https://www.youtube.com/watch?v=OqYeRjbR9PI.

Maritime and the Jones Act: Rights for Neches River and Gulf Workers

Many residents of the City of Kountze work as deckhands, tankermen, or engineers on the tugs and barges that navigate the Neches River and the Sabine-Neches Waterway. If you spend 30% or more of your time in service of a vessel, you are not covered by state workers’ comp. You are covered by the Jones Act (46 U.S.C. § 30104).

The Jones Act is the most powerful pro-worker law in America. It gives you the right to sue your maritime employer for negligence and provides a “featherweight” burden of proof—you only have to prove the employer’s negligence played the slightest part in your injury. You are also entitled to “Maintenance and Cure,” which is automatic, no-fault payment for your living expenses and medical bills until you reach maximum medical improvement. As Ralph explains in our “Ultimate Guide to Offshore Accidents” (https://www.youtube.com/watch?v=5vd_HVPtPf4), maritime law is highly specialized, and you need a firm that understands the deck of a ship as well as they understand a courtroom.

FELA: Protection for City of Kountze Railroad Workers

The City of Kountze has a deep history with the railroad, and current BNSF and Union Pacific lines still run through our region. Railroad workers do not have workers’ comp. Instead, you are protected by the Federal Employers Liability Act (FELA). Under FELA, you must prove the railroad was negligent, but the comparative negligence rules mean that even if you were partially at fault, you can still recover significant damages. If you were exposed to asbestos in locomotive brake shoes or inhaled diesel exhaust in the rail yards, FELA allows you to sue the railroad for your resulting cancers or respiratory diseases.

Bridge Content: When Toxic Exposure and Industrial Injury Collide

In the City of Kountze, it is rare for a worker to have just one type of claim. Most Southeast Texas industrial workers face “stacked” exposures and injury risks. This is where most law firms fail their clients—they focus on the immediate injury but ignore the latent toxic exposure, or they file a mesothelioma claim but miss the maritime negligence. At Attorney 911, we specialize in identifying the Bridge Claims that maximize your recovery.

The Shipyard-Asbestos Bridge

If you worked at the Todd Shipyards in Houston or the historical shipyards in Beaumont and Orange, you were likely a Jones Act seaman OR a worker covered by the Longshore and Harbor Workers’ Compensation Act (LHWCA). During your time in those shipyards, you were surrounded by chrysotile and amosite asbestos.

• Claim 1: A maritime negligence claim against the shipyard or vessel owner for unsafe working conditions.
• Claim 2: Multiple asbestos trust fund claims against the manufacturers of the insulation, gaskets, and pumps you handled.
• Result: A dual recovery strategy that can yield hundreds of thousands of dollars more than a single-track claim.

The Refinery-Benzene-Explosion Bridge

If you were injured in a process unit explosion at a refinery, like the 2005 BP Texas City event that Ralph Manginello litigated ($2.1B total case), your injuries are not just the immediate burns or blast trauma.

• Claim 1: A personal injury lawsuit for the catastrophic negligence that led to the explosion.
• Claim 2: A chronic chemical exposure claim if the investigation reveals long-term violations of the OSHA Benzene Standard (29 CFR 1910.1028). https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1028.
• Result: Compensation for the acute trauma and medical monitoring or damages for the long-term cancer risk caused by the facility’s safety failures.

The Oilfield-Silicosis-Crush Bridge

City of Kountze roughnecks and frac crew members in the East Texas or Permian Basin oilfields often suffer struck-by injuries from high-pressure lines.

• Claim 1: A Texas “non-subscriber” injury claim against employers who opted out of workers’ comp.
• Claim 2: A toxic exposure claim for silicosis caused by handling hydraulic fracturing sand (proppant) without proper respiratory protection.
• Result: We hold the drilling contractor, the operator, and the sand manufacturer accountable simultaneously.

Corporate Defendant Intelligence: The Companies Operating Near the City of Kountze

We don’t just sue insurance companies; we sue the corporate giants who built their fortunes on the backs of City of Kountze workers. In Southeast Texas, certain names appear repeatedly in our litigation files because of their documented history of safety violations and toxic exposures.

ExxonMobil (Beaumont and Baytown)

ExxonMobil operates one of the largest industrial complexes in the world just miles from the City of Kountze. Their record includes a $28.59 million verdict in Harris County in 2023 for a catastrophic plant explosion and a massive $725 million benzene-related leukemia verdict in 2024. If you worked at an Exxon facility, we ready to subpoena their internal industrial hygiene records.

Goodyear Tire & Rubber (Beaumont Chemical)

Hardin County residents have long staffed the Goodyear plant in Beaumont. Goodyear is currently facing over 62,000 active asbestos lawsuits nationwide. In 2024, a jury awarded $40.1 million in a mesothelioma case involving Goodyear’s asbestos-containing gaskets. We know their product history and we know their internal defense strategies.

Johns-Manville and the Asbestos Trust Template

Johns-Manville is the textbook example of corporate evil. Their own 1933 memos proved they knew their products were killing people, but they chose to “suppress” the data. JM was the first to use bankruptcy to shield themselves, establishing the Manville Trust. Today, that trust has paid out over $5 billion. We file claims with the Manville Trust and 60+ others for our City of Kountze clients. https://www.justice.gov/civil/common/reca.

Monsanto/Bayer (Roundup)

For our agricultural neighbors in Hardin County, the “Monsanto Papers” revealed that the company ghostwrote scientific studies to hide the connection between Roundup (glyphosate) and Non-Hodgkin Lymphoma. Landmark verdicts have topped $2 billion, proving that Southeast Texas juries have no patience for corporate lies. http://www.iarc.who.int/en/media-centre/iarcnews/2015/glyphosate.php.

Evidence Preservation: Why the First 30 Days in the City of Kountze Are Critical

Toxic exposure cases are won or lost on documentation. The corporations are counting on the fact that you won’t have your 1982 pay stubs or the name of the specific brand of insulation you used. At Attorney 911, we move immediately to stop the “routine” destruction of evidence. If you live in the City of Kountze, the moment you are diagnosed, we initiate our Spoliation Prevention Protocol:

1. Industrial Hygiene Capture: we demand the immediate preservation of all air sampling data and dosimeter readings from your specific unit at the refinery or plant.
2. Product Identification Genealogy: We use our massive database of Southeast Texas job sites to identify which manufacturers’ products—like Owens Corning Kaylo or Garlock gaskets—were present at your facility during your years of service.
3. Witness Preservation: We record depositions and statements from your former co-workers in the City of Kountze while their memories are fresh and before they scatter or pass away.
4. OSHA Log Subpoenas: We pull the OSHA 300 logs (29 CFR 1904) to prove that the company was patterns of injuries they were hiding from you. https://www.osha.gov/recordkeeping.

As Christopher Wick noted in his 5-star review: “Ralph & the Manginello law firm attorneys did more (in less than 8 weeks!) on my car accident case than a previous attorney who had the case for OVER a year.” In toxic torts, that speed is not just efficient—it is the difference between winning and losing.

Multiple Compensation Pathways: Maximize Your Recovery in Hardin County

One of the biggest mistakes a City of Kountze victim can make is thinking they only have “a lawsuit.” In reality, we often build a Compensation Stack for our clients that includes:

• Parallel Trust Fund Claims: Filing with 5 to 15 different asbestos bankruptcy trusts simultaneously. These pay relatively quickly and do not require a trial.
• Civil Litigation: Suing the still-solvent defendants (like John Crane or ExxonMobil) for full tort damages, including punitive awards.
• VA Disability: If you were exposed in the Navy or at a base like Camp Lejeune, we help you secure your U.S. Department of Veterans Affairs service-connected benefits. https://www.va.gov/disability/eligibility/hazardous-materials-exposure/camp-lejeune-water-contamination/.
• Social Security Disability (SSDI): Ensuring your federal disability payments are secured while your litigation is pending.

We don’t leave one dollar on the table. Other firms might just file one easy trust claim because they don’t want to do the hard work of litigating in federal court. Ralph Manginello is admitted to the U.S. District Court for the Southern District of Texas, and he is ready to take your case to the highest level.

Why Choose Attorney 911 for Your City of Kountze Case?

You have seen the mesothelioma commercials on TV. Most of those are lead-generation companies that haven’t set foot in a Southeast Texas courtroom in years. They take your information and sell it to the highest bidder. Attorney 911 is different.

We are local. We know the roads of the City of Kountze and the gates of the Port Arthur refineries. Ralph Manginello grew up in the Memorial area of Houston, attended South Texas College of Law, and has spent his entire career in the Texas legal system. When you call 1-888-ATTY-911, your case is handled by our team, not a call center.

Hablamos Español. We understand that a massive portion of the Southeast Texas workforce is Hispanic, and those workers were often given the most dangerous, highest-exposure jobs with the least protection. Lupe Peña is bilingual and understands the cultural nuances of our community. As Stephanie Hernandez shared: “Leonor immediately reassured me and took me seriously with no hesitation at all and she just really made me feel like I mattered throughout the entire process.” Your immigration status does NOT affect your right to a safe workplace or your right to sue for toxic exposure. Attorney Ralph Manginello’s 4-part immigration series on our podcast (https://share.transistor.fm/s/7787dfb4) explains these rights in detail.

No Fee Unless We Win. You are already facing the financial burden of advanced medical care at centers like the Michael E. DeBakey VA Medical Center or Baptist Beaumont Hospital. You should never have to pay for justice upfront. We work on a 100% contingency fee basis. We advance every dollar of the litigation costs—the expert toxicologists, the medical reviewers, the filing fees. If we don’t recover money for you, you owe us nothing.

FAQ: Toxic Exposure and Rights in the City of Kountze

Can I file a mesothelioma claim in the City of Kountze if my exposure was 40 years ago?

Yes. Texas follows the Discovery Rule. This means the statute of limitations (the deadline to file) does not start when you were exposed in the 1970s or 80s; it starts when you were diagnosed or when you reasonably should have known the exposure caused your illness. As Ralph explains in this podcast episode (https://share.transistor.fm/s/bddc1426), do not assume it is too late until we have reviewed your medical timeline.

How much is the average mesothelioma settlement in Southeast Texas?

While every case is unique, standard mesothelioma settlements frequently range between $1 million and $1.4 million, with trial verdicts often reaching much higher. Combined trust fund claims can add significantly to this total. Case values depend on your work history, the strength of product identification, and the number of dependents. At Attorney 911, we fight for the absolute maximum value. Past results do not guarantee future outcomes.

What if the company I worked for near the City of Kountze is bankrupt?

If your employer or a product manufacturer (like Johns-Manville or W.R. Grace) filed for bankruptcy, we can still recover money for you through their bankruptcy trust funds. There are 60-plus active trusts with over $30 billion in assets reserved specifically for toxic exposure victims. We prioritize these claims to get you money faster while we pursue other solvent defendants in court.

I worked at several different refineries—how do we know which one caused my cancer?

The law does not require us to prove that one specific fiber or one shift caused the disease. Under the “substantial factor” test, we only need to prove that each defendant’s product or negligence was a substantial factor in your cumulative exposure. Each company is “jointly and severally” liable, meaning they can’t point fingers at each other to avoid paying you.

Will my workers’ comp claim in the City of Kountze be affected if I sue a chemical manufacturer?

No. Workers’ comp is a separate administrative system. Filing a “third-party” lawsuit against the manufacturer of a toxic chemical or a defective piece of equipment is your right under Texas law and does not stop your workers’ comp benefits. In fact, a third-party claim is often the only way to recover the millions of dollars needed for lifelong medical care and family support.

Final Action: Your Fight for Justice Starts with One Call

The corporations that exposed you to asbestos and benzene in the City of Kountze and Southeast Texas have teams of lawyers, lobbyists, and insurance experts working right now to protect their profits. You deserve a team that is just as aggressive, just as sophisticated, and ten times more determined.

Ralph Manginello and Lupe Peña have the specialized knowledge, the Southeast Texas industrial experience, and the “Insider Advantage” needed to win these complex cases. We have earned our 4.9-star Google rating (based on 270+ reviews) by treating our clients like family and fighting their cases like they were our own. As Chad Harris said, we are the “PITT BULL” you need in your corner.

Do not let the money that was set aside for YOU stay in the hands of the corporations. Do not let your family’s future be stolen by a preventable disease. Call Attorney 911 right now at 1-888-ATTY-911 for a free, no-obligation consultation. Whether you are in the City of Kountze, Beaumont, Houston, or anywhere in Texas, we are ready to answer your call 24/7. Hablamos Español.

Attorney 911: Aggressive Representation for Toxic Exposure and Industrial Victims. Call 1-888-ATTY-911.

Principal office: Houston, Texas. Ralph Manginello is licensed in Texas and New York. Associated local counsel and pro hac vice admission used where required outside of primary licensure states. This content is for educational purposes and does not constitute legal advice. Past results do not guarantee future outcomes.