2014 01 29 Appellant's Brief

2953072
Case No. 13-10939

In the
United States Court of Appeals
for the Fifth Circuit

ALBERT G. HILL, III, INDIVIDUALLY, AND AS A BENEFICIARY OF THE MARGARET
HUNT TRUST ESTATE, DERIVATIVELY ON BEHALF OF THE MARGARET HUNT TRUST
ESTATE, INDIVIDUALLY, AS A BENEFICIARY OF THE HAROLDSON LAFAYETTE HUNT,
J R. TRUST ESTATE, AND DERIVATIVELY ON BEHALF OF THE HAROLDSON,
Plaintiff-Appellant,
v.

WILLIAM SCHILLING, INDIVIDUALLY AND IN HIS CAPACITY AS A MEMBER OF THE
ADVISORY BOARD M.H.T.E AND A MEMBER OF THE ADVISORY BOARD OF THE
H.H.T.E.; IVAN IRWIN, J R.; ALBERT G. HILL, J R.; ALINDA H. WIKERT; LYDA HILL;
HEATHER V. WASHBURNE; ELISA M. SUMMERS; MARGARET HUNT TRUST ESTATE;
HARDOLSON LAFAYETTE HUNT J R. TRUST ESTATE; WILLIAM HERBERT HUNT, IN HIS
CAPACITY AS THE PERSONAL REPRESENTATIVE OF THE ESTATE OF TOM HUNT; BRETT
RINGLE, INDIVIDUALLY AND IN HIS CAPACITY AS A MEMBER OF THE ADVISORY
BOARD OF THE M.H.T.E.; J OHN W. CREECY, INDIVIDUALLY AND IN HIS CAPACITY AS
TRUSTEE OF THE H.H.T.E.; MARGARET KELIHER, INDIVIDUALLY AND IN HER
CAPACITY AS TRUSTEE OF THE M.H.T.E. AND A MEMBER OF THE ADVISORY BOARD
OF THE H.H.T.E.,
Defendants-Appellees,
V.
STEPHEN MALOUF; LISA BLUE; BARON & BLUE; LAW OFFICES OF STEPHEN F.
MALOUF, P.C.; ALDOUS LAW FIRM; CHARLA ALDOUS; CHARLA ALDOUS, P.C.,
Intervenors Plaintiffs Appellees,
--------------------------------------
CAMPBELL HARRISON & DAGLEY, L.L.P.; CALLOWAY, NORRIS, BURDETTE &
WEBER, P.L.L.C.,
Intervenors Appellees.

Case: 13-10939 Document: 00512516055 Page: 1 Date Filed: 01/29/2014

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- ii -

On Appeal from the United States District Court
for the Northern District of Texas
No. 07-CV-02020-L, Sam A. Lindsay, J udge Presiding

BRIEF OF APPELLANT

Iian D. J ablon
Aarti K. Wilson
IRELL & MANELLA LLP
1800 Avenue of the Stars,
Suite 900
Los Angeles, California 90067
[Tel.] (310) 277-1010
[Fax] (310) 203-7199

ATTORNEYS FOR APPELLANT


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CERTIFICATE OF INTERESTED PERSONS
NO. 13-10939

ALBERT G. HILL III, INDIVIDUALLY AS A BENEFICIARY OF THE MARGARET HUNT
TRUST ESTATE, DERIVATIVELY ON BEHALF OF THE MARGARET HUNT TRUST
ESTATE, INDIVIDUALLY AS A BENEFICIARY OF THE HAROLDSON LAFAYETTE
HUNT, JR. TRUST ESTATE, AND DERIVATIVELY ON BEHALF OF THE HAROLDSON
LAFAYETTE HUNT, JR. TRUST ESTATE,
Plaintiff-Appellant,
v.

MARGARET KELIHER, BRETT RINGLE, J OHN CREECY, WILLIAM SCHILLING, IVAN
IRWIN J R. WILLIAM HERBERT HUNT, ALBERT G. HILL, J R. ALINDA H. WIKERT,
LYDA HILL, HEATHER H. WASHBURNE, AND ELISA H. SUMMERS,
Defendants-Appellees.

The undersigned counsel of record certifies the following listed persons have
an interest in the outcome of this case. These representations are made in order
that the judges of this court may evaluate their possible recusal or disqualification.
1. Plaintiff/Appellant is represented in the Fifth Circuit by:
Iian D. J ablon
Aarti K. Wilson
IRELL & MANELLA LLP
Suite 900


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Additional counsel who represented the Plaintiff/Appellant Albert G. Hill III
in the district court proceedings are:
Eric Chenoweth
Autry Ross
YETTER COLEMAN LLP
909 Fannin, Suite 3600
Houston, Texas 77010

Gregory S. Coleman
Christian J . Ward
Richard B. Farrer
YETTER COLEMAN LLP
221 West 6th Street, Suite 750
Austin, Texas 78701

Mark E. Smith
R. Wayne Gordon
TOUCHSTONE BERNAYS J OHNSTON
BEALL Smith &Stollenwerck LLP
4040 Renaissance Tower
1201 Elm Street
Dallas, Texas 75270

Alan Roy Struble
ALSTON & BIRD LLP
2200 Ross Avenue, Suite 3600
Dallas, Texas 75201

Brent R. Walker
Charla G. Aldous
ALDOUS LAW FIRM
2311 Cedar Springs Road, Suite 2200
Dallas, Texas 75201

Dana B. Taschner
DANA TASCHNER ATTORNEY AT LAW
2049 Century Park East, Suite 1940
David W. Evans
LAW OFFICES OF DAVID EVANS
2811 Turtle Creek Boulevard
Suite 1600
Dallas, Texas 75219

Dean D. Hunt
Matt R. Raley
Michelle D. Pector
BAKER & HOSTETLER LLP
1000 Louisiana, Suite 2000


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W. Mark Lanier
Eugene R. Egdorf
THE LANIER LAW FIRM PC
6810 FM 1960 West

J ames S. Renard
Melissa S. Yost
Michael J . Collins
William A. Brewer, III
BICKEL & BREWER
1717 Main Street, Suite 4800
Dallas, Texas 75201

J ohn C. Hueston
Michael G. Ermer
IRELL & MANELLA LLP
840 Newport Center Drive, Suite 400
Newport Beach, California 92660

Stephen F. Malouf
J onathan Andrew Nockels
THE LAW OFFICES OF STEPHEN F.
MALOUF PC
Suite 1600
Dallas, Texas 75219

J ustin M. Campbell, III
Kenneth J . Fair
Robin L. Harrison
Suzanne E. Goss
CAMPBELL HARRISON & DAGLEY LLP
4000 Two Houston Center
909 Fannin Street, Suite 4000

Lisa A. Blue
BARON & BLUE
5956 Sherry Lane, Suite 1616
Dallas, Texas 75225
Elizabeth A. Scully
Mark A. Cymrot
1050 Connecticut Avenue NW
Suite 1100
Washington, DC 20036

Marshall A. Camp
IRELL & MANELLA LLP
1800 Avenue of the Stars, Suite 900

R. Dean Gresham
GRESHAM PC
Dallas, Texas 75201

Evan M. J anush
126 East 56th Street
Tower 56, 6th Floor
New York, New York 10022


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Counsel who represented Defendant/Appellee Tom Hunt in the district court
proceedings are:
George W. Bramblett, J r.
Carrie L. Huff
HAYNES & BOONE, LLP
2323 Victory Avenue, Suite 700
Dallas, Texas 75219

J oseph W. Wagner
HAYNES & BOONE LLP
Dallas, Texas 75202
Counsel who represented Defendant/Appellee William Schilling in the
district court proceedings are:
Carrie L. Huff
David A. Dodds
HAYNES & BOONE LLP
Dallas, Texas 75219

David J . Beck
Murray Fogler
BECK REDDEN & SECREST LLP
1221 McKinney Street, Suite 4500

J oseph W. Wagner
HAYNES & BOONE LLP
Dallas, Texas 75202

Counsel who represented Defendant/Appellee Ivan Irwin, J r. in the district
court proceedings are:
Harry M. Reasoner
VINSON & ELKINS LLP

Michael L. Raiff
GIBSON DUNN & CRUTCHER LLP
2100 McKinney Avenue, Suite 1100
Dallas, Texas 75201


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William D. Sims, J r.
VINSON & ELKINS LLP
Dallas, Texas 75201

Counsel who represented Defendant/Appellee Albert G. Hill, J r. in the
J . Keith Benedict
A G HILL PARTNERS LLC
1601 Elm Street, Suite 5000
Dallas, Texas 75201

Amanda R. Tyler
Eric W. Pinker
Kent D. Krabill
LYNN TILLOTSON & PINKER LLP
750 N. St. Paul Street, Suite 1400
Dallas, Texas 75201

C. Gregory Shamoun
Dennis M. Holmgren
J ames R. Tucker
J onathan J . Cunningham
SHAMOUN & NORMAN LLP
1775 Wittington Place
Suite 200 LB 25
Dallas, Texas 75234

Michael L. Raiff
J ames C. Ho
Dallas, Texas 75201
Michael P. Lynn
J eremy A. Fielding
Richard A. Smith
LYNN TILLOTSON PINKER & COX LLP
2100 Ross Avenue, suite 2700
Dallas, Texas 75201

Robert H. Thomas
Peter M. J ung
STRASBURGER & PRICE
Dallas, Texas 75250


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Counsel who represented Defendant/Appellee Alinda H. Wikert in the
Donald E. Godwin
Bruce W. Bowman, J r.
Israel R. Silvas
J enny L. Martinez
Robert J . McGuire
W. Ira Bowman
GODWIN PAPPAS & RONQUILLO PC
Dallas, Texas 75270

Counsel who represented Defendant/Appellee Lyda Hill in the district court
proceedings are:
Frank N. Ikard, J r.
Lauren K. Davis
Laurie Ratliff
Mary E. Haught
IKARD GOLDEN PC
Austin, Texas 78701

J ames D. Brown
Michael P. Massad
WINSTEAD PC
1201 Elm Street
Dallas, Texas 75201

Russell A. Devenport
MCDONALD SANDERS
Fort Worth, Texas 76102

Kirk Todd Florence
J ennifer L. Graf
CROUCH & RAMEY, L.L.P.
Dallas, TX 75202


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Counsel who represented Defendant/Appellee Heather V. Washburne in the
Stewart H. Thomas
Tom M. Dees, III
HALLETT & PERRIN PC
2001 Bryan Street, Suite 3900
Dallas, Texas 75201

Counsel who represented Defendant/Appellee Elisa M. Summers in the
Stewart H. Thomas
Tom M. Dees, III
HALLETT & PERRIN PC
Dallas, Texas 75201

Counsel who represented Defendant/Appellee William Herbert Hunt in the
B. Patrick Shaw
WOODWARD & SHAW
4849 Greenville Avenue, Suite 1111
Dallas, Texas 75206

Counsel who represented Defendant/Appellee Margaret Hunt Trust Estate in
the district court proceedings are:
Carrie L. Huff
HAYNES & BOONE LLP
Dallas, Texas 75219

David J . Beck
Murray Fogler


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J oseph W. Wagner
HAYNES & BOONE LLP
Dallas, Texas 75202

Counsel who represented Defendant/Appellee Haroldson Lafayette Hunt J r.
Trust Estate in the district court proceedings are:
Carrie L. Huff
David A. Dodds
HAYNES & BOONE LLP
Dallas, Texas 75219
David J . Beck
Murray Fogler

J oseph W. Wagner
HAYNES & BOONE LLP
Dallas, Texas 75202

Counsel who represented Defendant/Appellee Brett Ringle in the district
Stephen D. Susman
Thomas W. Paterson
SUSMAN GODFREY LLP
First Interstate Plaza
1000 Louisiana Street, Suite 1500

Carrie L. Huff
David A. Dodds
HAYNES & BOONE LLP
Dallas, Texas 75219
David J . Beck
Murray Fogler

Stephen Shackelford, J r.
SUSMAN GODFREY LLP
Dallas, Texas 75202


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Counsel who represented Defendant/Appellee J ohn W. Creecy in the district
Stephen D. Susman
Thomas W. Paterson
SUSMAN GODFREY LLP

Carrie L. Huff
David A. Dodds
HAYNES & BOONE LLP
Dallas, Texas 75219
David J . Beck
Murray Fogler

Stephen Shackelford, J r.
SUSMAN GODFREY LLP
Dallas, Texas 75202

Counsel who represented Defendant/Appellee Margaret Keliher in the
Eric T. Stahl
Frank L. Branson
Quentin Brogdon
LAW OFFICES OF FRANK L. BRANSON
4514 Cole Avenue, Suite 1800
Dallas, Texas 75205

Carrie L. Huff
David A. Dodds
HAYNES & BOONE LLP
Dallas, Texas 75219
David J . Beck
Murray Fogler

Gilbert I. Low
ORGAIN BELL & TUCKER
P.O. Box 1751
470 Orleans Street
Beaumont, Texas 77704


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Counsel who represented Intervenor Plaintiff Stephen Malouf in the district
Stephen F. Malouf
J onathan A. Nockels
MALOUF, P.C.
Suite 1600
Dallas, Texas 75219

Alan S. Loewinsohn
Kerry F. Schonwald
LOEWINSOHN FLEGLE DEARY LLP
12377 Merit Drive, Suite 900
Dallas, Texas 75251

David W. Evans
Suite 1600
Dallas, Texas 75219

Counsel who represented Intervenor Plaintiff Lisa Blue in the district court
proceedings are:
Lisa A. Blue
BARON & BLUE
Dallas, Texas 75225

Alan S. Loewinsohn
Kerry F. Schonwald
Dallas, Texas 75251

Counsel who represented Intervenor Plaintiff Erin Nance Hill in the district
Charla G. Aldous
Brent Walker
ALDOUS LAW FIRM
Dallas, Texas 75201

J ohn H. Barr
J ohn H. House, J r.
Lucas Radney
M. Forest Nelson
BURT BARR & ASSOCIATES
203 East Colorado Boulevard
Dallas, Texas 75222

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Counsel who represented Intervenor Plaintiff Baron & Blue in the district
Lisa A. Blue
BARON & BLUE
Dallas, Texas 75225

Alan S. Loewinsohn
Kerry F. Schonwald
Dallas, Texas 75251

Counsel who represented Intervenor Plaintiff Law Offices of Stephen F.
Malouf, PC in the district court proceedings are:
Alan S. Loewinsohn
Kerry F. Schonwald
Dallas, Texas 75251
David W. Evans
Suite 1600
Dallas, Texas 75219

Stephen F. Malouf
MALOUF PC
Suite 1600
Dallas, Texas 75219

Counsel who represented Intervenor Plaintiff Aldous Law Firm in the
Alan S. Loewinsohn
Kerry F. Schonwald
Dallas, Texas 75251

Charla G. Aldous
Brent R. Walker
ALDOUS LAW FIRM
Dallas, Texas 75201


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Counsel who represented Intervenor Plaintiff Charla Aldous in the district
Alan S. Loewinsohn
Kerry F. Schonwald
Dallas, Texas 75251

Charla G. Aldous
ALDOUS LAW FIRM
Dallas, Texas 75201

Counsel who represented Intervenor Plaintiff Charla Aldous, PC in the
Alan S. Loewinsohn
Kerry F. Schonwald
Dallas, Texas 75251

Charla G. Aldous
Brent R. Walker
ALDOUS LAW FIRM
Dallas, Texas 75201

Counsel who represented Intervenor Plaintiff Thompson-Huffman Limited
Partnership in the district court proceedings are:
J ason Poe
Lee H. Ayres
S. Todd Parks
AYRES WARREN SHELTON & WILLIAMS,
L.L.C.
333 Texas Street, 14th Floor
Shreveport, LA 71101


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Counsel who represented Respondent The Aldous Law Firm in the district
Alan S. Loewinsohn
Kerry F. Schonwald
Dallas, Texas 75251

Charla G. Aldous
Brent R. Walker
ALDOUS LAW FIRM
Dallas, Texas 75201

Counsel who represented Respondent R. Dean Gresham in the district court
proceedings are:
Alan S. Loewinsohn
Kerry F. Schonwald
Dallas, Texas 75251
R. Dean Gresham
GRESHAM PC
Dallas, Texas 75201

Counsel who represented Movant Ellen Flowers in the district court
proceedings are:
Ryan K. McComber
A. Erin Dwyer
FIGARI & DAVENPORT, L.L.P.
3400 Bank of America Plaza
901 Main Street, LB 125
Dallas, Texas 75202

Counsel who represented Movant J oyce Waller in the district court
proceedings are:
Michael P. Lynn
Richard A. Smith
LYNN TILLOTSON PINKER & COX LLP
Dallas, Texas 75201

Kent D. Krabill
LYNN TILLOTSON & PINKER LLP
750 N. St. Paul Street, Suite 1400
Dallas, Texas 75201


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Robert H. Mow, J r.
Alison R. Ashmore
Danny S. Ashby
J ennifer B. Landry
K&L GATES
Dallas, Texas 75201
Counsel who represented Movant Michael V. Bourland in the district court
proceedings are:
David J . Goodman
William R. Korb, J r.
Eric J . Millner
BOURLAND WALL & WENZEL PC
301 Commerce Street, Suite 1500

Counsel who represented Movant Stewart H. Thomas in the district court
proceedings are:
C. Shawn Cleveland
Emily C. McCall
Matthew D. Orwig
SNR DENTON US LLP
2000 McKinney Avenue, suite 1900
Dallas, Texas 75201

Counsel who represented Movant Tom M. Dees, III in the district court
proceedings are:
C. Shawn Cleveland
Emily C. McCall
Matthew D. Orwig
SNR DENTON US LLP
2000 McKinney Avenue, suite 1900
Dallas, Texas 75201


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Counsel who represented Movant Shamoun & Norman, LLP in the district
Daniel D. Tostrud
COBB MARTINEZ WOODWARD PLLC
1700 Pacific, Suite 3100
Dallas, Texas 75201

C. Gregory Shamoun
J onathan J . Cunningham
Amanda M. Hoffmann
SHAMOUN & NORMAN LLP
1775 Wittington Place
Suite 200 LB 25
Dallas, Texas 75234

Angela M. Hough
HERMES SARGENT BATES LLP
Dallas, Texas 75202

Counsel who represented Movant PBL Multi-Strategy Fund, L.P. in the
Lawrence S. Fischman
Troy David Phillips
GLAST PHILLIPS & MURRAY PC
Dallas, Texas 75201

The Guardian ad Litem in the district court proceedings is:
Michael K. Hurst
Dena DeNooyer Stroh
GRUBER HURST J OHANSEN & HAIL LLP
Dallas, Texas 75202


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Counsel who represented Interested Party Ron Cresswell in the district court
proceedings are:
William A. Barr
Sara N. Copeland
LOCKE LORD BISSELL & LIDDELL LLP
Dallas, Texas 75201

Counsel who represented Interested Party Locke Lord Bissell & Liddell LLP
in the district court proceedings are:
William A. Barr
Sara N. Copeland
LOCKE LORD BISSELL & LIDDELL LLP
Dallas, Texas 75201

Counsel who represented Interested Party XTO Energy Inc. in the district
Mitchell M. Murphy
J effrey C. King
WINSTEAD PC

Counsel who represented Interested Party J onathan Nockels in the district
Alan S. Loewinsohn
Dallas, Texas 75251


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Counsel who represented Interested Party Brent Walker in the district court
proceedings are:
Alan S. Loewinsohn
Dallas, Texas 75251

Counsel who represented Interested Party David Evans in the district court
proceedings are:
Alan S. Loewinsohn
Dallas, Texas 75251

Counsel who represented Interested Party Gresham PC in the district court
proceedings are:
R. Dean Gresham
GRESHAM PC
Dallas, Texas 75201

Alan S. Loewinsohn
Kerry F. Schonwald
Dallas, Texas 75251

Counsel who represented Receiver Daniel L. J ackson in the district court
proceedings are:
Talmage Boston
WINSTEAD PC
1201 Elm Street
Dallas, Texas 75270


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Counsel who represented Trustee Larry E. J acobs in the district court
proceedings are:
Larry E. J acobs
BOYER J ACOBS SHORT
Nine Greenway Plaza, Suite 3100

Counsel who represented Trustee Peggy Allison in the district court
proceedings are:
Carrie L. Huff
HAYNES & BOONE LLP
Dallas, Texas 75219

Counsel who represented Trustee Danny Bowlin in the district court
proceedings are:
Carrie L. Huff
HAYNES & BOONE LLP
Dallas, Texas 75219

Counsel who represented Trustee Chester Donnally in the district court
proceedings are:
Carrie L. Huff
HAYNES & BOONE LLP
Dallas, Texas 75219


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Counsel who represented Intervenor Campbell Harrison & Dagley LLP in
the district court proceedings are:
Robert W. Calloway
Mary C. Burdette
CALLOWAY NORRIS BURDETTE &
WEBER
3811 Turtle Creek, Suite 400
Dallas, Texas 75219

Kenneth J . Fair
Robin L. Harrison
Suzanne E. Goss

Counsel who represented Intervenor Calloway, Norris, Burdette & Weber,
PLLC in the district court proceedings are:
Kenneth J . Fair
Robin L. Harrison
Suzanne E. Goss

Robert W. Calloway
Mary C. Burdette
CALLOWAY NORRIS BURDETTE &
WEBER
3811 Turtle Creek, Suite 400
Dallas, Texas 75219

Counsel who represented Counter Claimant Lyda Hill in the district court
proceedings are:
Laurie Ratliff
Mary E. Haught
IKARD GOLDEN PC
Austin, Texas 78701

J ames D. Brown
Michael P. Massad
WINSTEAD PC
1201 Elm Street
Dallas, Texas 75201

Russell A. Devenport
MCDONALD SANDERS


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Counsel who represented Counter Defendant Albert G. Hill, III in the district
Mark E. Smith
R. Wayne Gordon
TOUCHSTONE BERNAYS J OHNSTON
BEALL SMITH & STOLLENWERCK LLP
1201 Elm Street
Dallas, Texas 75270

Alan Roy Struble
ALSTON & BIRD LLP
Dallas, Texas 75201

Brent R. Walker
Charla G. Aldous
ALDOUS LAW FIRM
Dallas, Texas 75201

Dana B. Taschner
DANA TASCHNER ATTORNEY AT LAW
2049 Century Park East, Suite 1940
David W. Evans
Suite 1600
Dallas, Texas 75219

Dean D. Hunt
Elizabeth A. Scully
Matt R. Raley
Michelle D. Pector
BAKER & HOSTETLER
1000 Louisiana, Suite 2000

Eugene R. Egdorf
Evan M. J anush
W. Mark Lanier
6810 FM 1960 West

J ames S. Renard
Melissa S. Yost
Michael J . Collins
William A. Brewer, III
BICKEL & BREWER
Dallas, Texas 75201

J ohn C. Hueston
Michael G. Ermer
IRELL & MANELLA LLP
840 Newport Center Drive, Suite 400
Newport Beach, California 92660
Stephen F. Malouf
MALOUF PC

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Suite 1600
Dallas, Texas 75219

Kenneth J . Fair
Robin L. Harrison
Suzanne E. Goss

Lisa A. Blue
BARON & BLUE
Dallas, Texas 75225
Mark A. Cymrot
1050 Connecticut Avenue NW
Suite 1100
Washington, DC 20036

Marshall A. Camp
IRELL & MANELLA LLP
1800 Avenue of the Stars, Suite 900

R. Dean Gresham
GRESHAM PC
Dallas, Texas 75201

Gregory S. Coleman
Christian J . Ward
Richard B. Farrer
YETTER COLEMAN LLP
221 West Sixth Street, Suite 750
Austin, Texas 78701

Counsel who represented Counter Claimant Alinda H. Wikert, III in the
Donald E. Godwin
Israel R. Silvas
J enny L. Martinez
Robert J . McGuire
W. Ira Bowman
GODWIN PAPPAS & RONQUILLO PC
Dallas, Texas 75270


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Counsel who represented Counter Claimant Heather V. Washburne in the
Stewart H. Thomas
Tom M. Dees, III
HALLETT & PERRIN PC
Dallas, Texas 75201

Counsel who represented Counter Claimant Elisa M. Summers in the district
Stewart H. Thomas
Tom M. Dees, III
HALLETT & PERRIN PC
Dallas, Texas 75201

/s/ Aarti K. Wilson
Aarti K. Wilson

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STATEMENT REGARDING ORAL ARGUMENT
Appellant believes that oral argument will assist the Court in resolving this
case. The core issue in this appeal is straightforward: whether the district court
erred in ruling that successor trustees for a trust that was partitioned for
Appellants benefit in 2010 as part of the parties settlement in this action have no
right to obtain copies of the archives and permanent records of the original trust.
However, because the underlying litigation involved numerous parties and non-
party participants, was complex and protracted, and has generated a lengthy and
complicated record, oral argument will significantly benefit the Court in applying
the law on the complex record of this case.
TABLE OF CONTENTS
Page
2953072
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Certificate of Interested Persons ............................................................................ iii
Statement Regarding Oral Argument ................................................................. xxv
Statement of J urisdiction ......................................................................................... 1
Statement of Issues for Review ............................................................................... 1
Introduction ............................................................................................................. 1
Statement of Facts and of the Case ......................................................................... 5
A. The Articles of Agreement of the Margaret Hunt Trust Estate ......... 5
B. The Underlying Litigation .................................................................. 6
C. The District Court Refuses to Order the Former Trustees to
Provide the Archives and Permanent Records of the MHTE
to the Successor Trustees ................................................................... 9
Standard of Review ............................................................................................... 13
Summary of the Argument .................................................................................... 13
Argument............................................................................................................... 14
I. The Successor Trustees of the Sub-Trusts Created From the MHTE
Are Entitled to Copies of the Archives and Permanent Records of
the MHTE. .................................................................................................. 14
A. The MHTEs Articles of Agreement Provide that a Successor
Trustee Shall Have the Same Rights as the Prior Trustee. ............... 14
B. Texas Law Is Fully Consistent with the MHTEs Articles of
Agreement with Respect to the Successor Trustees Rights. ........... 19
C. Hill III Presented Undisputed Evidence that the Successor
Trustees Have a Legitimate Need to Access the Permanent
Records of the MHTE. ..................................................................... 20
Page
2953072
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D. The Prior Trustees Are Not Being Asked to Provide a Trust
Accounting. ..................................................................................... 24
E. The Other Objections Raised by Appellees Lack Merit. ................. 27
II. At a Minimum, J udge Soliss J uly 30, 2013 Order Should Be Vacated
or Remanded to the District Court, Because He Was Apparently
Operating under an Undisclosed Conflict. ................................................. 29
Conclusion ............................................................................................................ 31

TABLE OF AUTHORITIES
Page(s)
2953072
- xxviii -

Cases
Goldin v. Bartholow,
166 F.3d 710 (5th Cir. 1999) ............................................................................... 13
Hill v. Schilling,
495 Fed. Appx. 480 (5th Cir. 2012) ................................................................... 10
Hoenig v. Texas Commerce Bank, N.A.,
939 S.W.2d 656 (Tex. App. San Antonio 1996) .............................................. 23
Huie v. DeShazo,
922 S.W.2d 920 (Tex. 1996) ................................................................................ 28
In re Bradley,
501 F.3d 421 (5th Cir. 2007) ............................................................................... 28
Interfirst Bank-Houston, N.A. v. Quintana Petroleum Corp.,
699 S.W.2d 864 (Tex. App. Houston [1st Dist.] 1985) .................................... 28
Liljeberg v. Health Servs. Acquisition Corp.,
486 U.S. 847 (1988) ............................................................................................. 30
Rohrbach v. AT&T Nassau Metals Corp.,
915 F. Supp. 712 (M.D. Pa. 1996) ....................................................................... 31
Statutes
28 U.S.C. 1291 ......................................................................................................... 1
28 U.S.C. 1441(a) .................................................................................................... 1
Tex. Prop. Code 112.054 ...................................................................................... 19
Tex. Prop. Code 112.057 ...................................................................................... 19
Tex. Prop. Code 113.084 ...................................................................................... 19
Tex. Prop. Code 113.151 ...................................................................................... 25
Tex. Prop. Code 113.152 ...................................................................................... 25
Page(s)
2953072
- xxix -

Rules
Fed. R. Civ. P. 60(b) ................................................................................................ 11
Fed. R. Civ. P. 72 ..................................................................................................... 11


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STATEMENT OF JURISDICTION
Defendants-Appellees invoked the district courts jurisdiction pursuant to 28
U.S.C. 1441(a), which allows the removal of any civil action brought in a State
Court of which the district courts of the United States have original jurisdiction.
This Court has jurisdiction over this appeal pursuant to 28 U.S.C. 1291.
STATEMENT OF ISSUES FOR REVIEW
1. Whether the district court erred in ruling that the successor trustees of a
1935 trust that was partitioned in 2010 for Appellants benefit are not
entitled to obtain copies of the archives and permanent records of the
partitioned trust.
2. Whether the district courts order refusing to grant the successor trustees
access to the permanent records of the trust should be vacated and
remanded because the district court judge recused himself without
explanation shortly after entering the order, and thus was apparently
operating under a conflict of interest at the time he entered the ruling.
INTRODUCTION
The underlying litigation was a bitter intra-family dispute over an
inheritance exceeding $1 billion, a significant part of which was held in the
Margaret Hunt Trust Estate (the MHTE), a trust that had been established in
1935 by legendary oil tycoon H.L. Hunt. After nearly two-and-a-half years of
litigation, the parties entered into a written settlement agreement in May 2010,
which was implemented by the district court in a final judgment entered in
November 2010.

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Among other things, the final judgment divided the MHTE into several
separate and independent sub-trusts, including one such sub-trust for the benefit of
Appellant Albert G. Hill, III
1
(the MHTE-Albert G. Hill III Trust, hereinafter the
MHTE-Hill III Trust), and another such sub-trust as to which Appellant is the
remainder beneficiary (the MHTE-Albert G. Hill, J r. Income Beneficiary/Hill III
Termination Beneficiary Trust, hereinafter the Hill III Termination Trust). The
final judgment also appointed successor trustees to administer each of the various
sub-trusts.
The sub-trusts, with three limited exceptions described in the final judgment,
continue to be governed by the original 1935 Articles of Agreement and
Declaration of Trust that established the MHTE, and are expressly continuations of
the original 1935 trust.
The MHTEs Articles of Agreement provide that a successor trustee inherits
all of the rights and responsibilities of the former trustee. Among the rights and
responsibilities of the trustee are the duties to keep accurate records and books of
account regarding the trust, and to maintain the archives and permanent records
of the trust. (ROA.17765) (Record Excerpts (RE) Tab 5).

1
Appellant is referred to herein as Hill III. Hill III is sometimes referred to in
materials filed in the district court proceedings as Al III. Likewise, Hill IIIs
father, Albert G. Hill, J r., is referred to herein as Hill J r., but is sometimes
referred to in materials filed in the district court as Al J r.

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After the MHTE was partitioned as required by the final judgment in 2010,
the successor trustees of the MHTE-Hill III Trust and the Hill III Termination
Trust requested that Appellees make the books and records of the MHTE available
for copying by the successor trustees. Appellees refused, contending that the
successor trustees for the sub-trusts affiliated with Hill III have no right to obtain
copies of the archives and permanent records of the MHTE.
With the support of the successor trustees, Hill III thereafter moved the
district court for an order compelling Appellees to either make the books and
records of the MHTE available for copying by the successor trustees, or to make
the records available for copying by Hill III personally. The district court denied
that motion, reasoning that (1) nothing in the final judgment or in the MHTEs
Articles of Agreement specifically requires that the former trustee of the MHTE
provide copies of the trusts books and records to a successor trustee, and (2) Hill
III had agreed in the parties settlement agreement that the former trustees would
not be required to furnish any trust accounting in connection with the settlement,
and thus Hill III was precluded from obtaining the books and records of the trust.
As explained more fully below, the district courts ruling on Hill IIIs
motion is erroneous. Under the terms of the Articles of Agreement and under
Texas law, a successor trustee inherits all of the same rights, powers, duties, and
obligations of his or her predecessor. In this case, such rights necessarily include

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reasonable access to the archives and permanent records of the trust materials
that the Articles of Agreement clearly state belong to the trust, and not to the
trustee personally. Moreover, neither Hill III nor the successor trustees have
requested that the prior trustees provide an accounting the successor trustees
have simply requested copies of the permanent records of the trust, which is
entirely different than requesting that the prior trustee prepare a trust accounting.
Further, there is no support whatsoever for the district courts implicit ruling that
successor trustees for some of the sub-trusts created from the MHTE are entitled to
complete copies of the books and records of the original trust, but successor
trustees for other sub-trusts (i.e., those affiliated with Hill III) are not entitled to
those same materials.
For all of these reasons, and as discussed more fully below, the district court
erred in denying Hill IIIs motion to compel Appellees to produce copies of the
MHTEs books and records to the successor trustees.
In the alternative, this Court should vacate the order at issue and remand Hill
IIIs motion for consideration by the new district court judge assigned to hear this
action based upon the fact that the district court judge who decided the motion that
gives rise to this appeal recused himself, without explanation, shortly after entering
the order that is being appealed from, and was thus apparently operating under a

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conflict of interest at the time the order at issue which is intemperate and
disparaging of Hill III was entered.
STATEMENT OF FACTS AND OF THE CASE
A. The Articles of Agreement of the Margaret Hunt Trust Estate
In 1935, oil tycoon H.L. Hunt, then reportedly the wealthiest man in the
United States, established irrevocable trusts for six of his children, including
Margaret Hunt Hill (Margaret, the original beneficiary of the Margaret Hunt
Trust Estate (MHTE)) and Hassie Lafayette Hunt J r. (the original beneficiary of
the Haroldson Hunt Trust Estate (HHTE)).
The Articles of Agreement and Declaration of Trust establishing each of the
MHTE and HHTE were substantively identical and set forth guidelines for the
administration of the trusts. The Articles of Agreement of the MHTE establish the
duties of the trustee. Among other things, the trustee is required to
keep, or cause to be kept, faithful records and books of
account, reflecting at all times the true conditions of the affairs
of said Trust Estate, which said records and books of account
shall at all times be open for the inspection of the other two
members of the Advisory Board, and as near after the close of
each calendar year as is reasonably possible the Trustee shall
have said books and records audited by a Certified Public
Accountant and a report of said audit filed as a part of the
archives and permanent records of said Trust Estate . . . .

(ROA.17765) (emphasis added) (RE Tab 5).

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The Articles of Agreement further provide that when the trustee is replaced,
the successor trustee shall succeed to the same rights and powers and be subject to
the same duties and liabilities as his predecessor, with such rights vesting
immediately upon being elected as successor trustee. (ROA.17761) (RE Tab 5).
B. The Underlying Litigation
The factual background of this litigation has been summarized at length for
this Court in connection with Hill IIIs original appeal from the final judgment.
See Hill v. Schilling, Case No. 11-10348, Appellants Br. at 3-15 (5th Cir., filed
Oct. 17, 2011). In brief: In 2005, Hill IIIs father, Albert G. Hill, J r. (Hill J r.),
signed an irrevocable disclaimer of a portion of his interest in the MHTE in favor
of his children. When Margaret died in 2007, Hill J r.s interest in the MHTE
vested and, by virtue of the disclaimer Hill J r. had signed in 2005, Hill J r.s
children (including Hill III) became vested, current beneficiaries of the MHTE.
Apparently hoping to avoid certain tax consequences that would result from
the 2005 disclaimer, shortly after Margarets death in 2007, Hill J r. executed an
updated but substantially similar disclaimer in favor of his children (including Hill
III). Soon thereafter, however, Hill J r. took the position that the disclaimer he had
signed in 2005 was invalid based on the contention that Hill J r. had purportedly
been incompetent when he signed it. (See ROA.10746). Hill J r. also took the
position that his 2007 disclaimer had been signed in 2005, at a time when he was

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purportedly incompetent. (See ROA.10748). In late 2007, Hill J r. filed pleadings
in state court in Texas seeking to establish that the disclaimers he had signed were
invalid, and that Hill III was therefore not a beneficiary of the MHTE.
(ROA.11587-94).
In response, on November 8, 2007, Hill III filed a suit in the 14th J udicial
District of Dallas County, alleging that his father and others had committed
violations of the federal Racketeer Influenced and Corrupt Organizations Act
(RICO), fraud, breach of fiduciary duty, and other torts in connection with the
MHTE and the HHTE. (ROA.186-231). Hill IIIs lawsuit, which the Defendants
removed to the United States District Court for the Northern District of Texas on
December 3, 2007, sought various forms of relief, including a declaration that Hill
III was a beneficiary of both the MHTE and the HHTE. (ROA.155-61, 229-30).
After nearly two and a half years of litigation, the parties entered into a
written Global Settlement and Mutual Release Agreement (the GSA or
Settlement Agreement) that was filed with the district court in May 2010.
(ROA.Sealed, Dkt.879). Among the agreed-upon settlement terms was that the
MHTE would be divided pro rata into separate sub-trusts for each of the current
beneficiaries, including Hill III. (ROA.Sealed, Dkt.879 at 7, 17) (RE Tab 10). The
parties agreed that each sub-trust would be separately administered by new
successor trustees in accordance with the 1935 Articles of Agreement of the

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MHTE. (ROA.Sealed, Dkt.879 at 17, 23) (RE Tab 10). The parties also agreed
that the outgoing trustees of the MHTE would be released for failure to furnish
any trust accounting for either of the MHTE or the HHTE, for time periods before
and including the resignation dates of the trustees and advisory board members.
(ROA.Sealed, Dkt. 879 at 24-25) (RE Tab 10).
On November 8, 2010, after the parties had submitted lengthy briefing
concerning implementation of the Settlement Agreement, the district court entered
its final judgment (the Final J udgment) that purported to implement the
Settlement Agreement. As required by the Settlement Agreement, the Final
J udgment divided the MHTE into several sub-trusts as of the date of Margarets
death (J une 14, 2007), and appointed successor trustees to oversee each of the
sub-trusts. (ROA.Sealed, Dkt.999 at 7-20). One such sub-trust was created for the
benefit of Hill III (the MHTE-Hill III Trust) and another such sub-trust was created
as to which Hill III is the remainder beneficiary (Hill III Termination Trust).
(ROA.Sealed, Dkt.999 at 7-8, 12-14, 20) (RE Tab 9).
The Final J udgment provides that, with three minor modifications that are
not relevant to this appeal, each of the sub-trusts created from the MHTE shall be
governed by the terms and provisions of the [1935] Articles of Agreement and
Declarations of Trust establishing the MHTE . . . . (ROA.Sealed, Dkt.999 at 2,
24-25) (RE Tab 9).

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C. The District Court Refuses to Order the Former Trustees to
Provide the Archives and Permanent Records of the MHTE to
the Successor Trustees
Due to the passage of time between the parties settlement in May 2010 and
the district courts entry of the Final J udgment in November 2010, shortly after the
Final J udgment was entered, Hill III filed a motion requesting that the district court
alter or amend the Final J udgment to require the former trustees of the MHTE to
provide him with a trust accounting for the period between May and November
2010. (ROA.Sealed, Dkt.1050 at 14-15). The district court rejected that request,
citing the provision of the Settlement Agreement which states that the former
trustees are released for any failure to furnish any trust accounting for either the
MHTE or the HHTE. (ROA.Sealed, Dkt.1099 at 11 (RE Tab 8); see also
ROA.Sealed, Dkt.879 at 24-25 (RE Tab 10)).
Hill III then filed an appeal to this Court relating to certain provisions of the
Final J udgment that deviated from the parties Settlement Agreement. (See
ROA.17486-87; Hill v. Hunt, et al., 5th Cir. Case No. 11-10348). While that
appeal was pending, Hill III learned that the district court judge who had been
presiding over the action since 2007 (the Honorable Reed OConnor) apparently
had an undisclosed conflict of interest both at the time the Settlement Agreement
had been signed and when the Final J udgment had been entered. In March 2012,
Hill III unsuccessfully moved to recuse J udge OConnor, and then appealed the

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denial of his motion to recuse to this Court. (ROA.Sealed, Dkt. 1257, ROA.17829-
83; Hill v. Hunt, et al., 5th Cir. Case No. 12-10620). Hill IIIs two appeals were
consolidated,
2
and this Court ultimately ruled against Hill III. Hill v. Schilling, 495
Fed. Appx. 480, 483 (5th Cir. 2012). Soon after the mandate issued, however,
J udge OConnor abruptly recused himself without explanation and was eventually
replaced by the Honorable J orge A. Solis. (ROA.149, 18112-13).
Meanwhile, in December 2010, the MHTE had been divided into sub-trusts
as required by the parties Settlement Agreement and the Final J udgment.
(ROA.Sealed, Dkt. 1053). After the division took place, the successor trustees of
the MHTE-Hill III Trust and the Hill III Termination Trust requested that the
predecessor trustees of the MHTE provide the successor trustees with copies of (or
access to) the books and records of the MHTE. (ROA.17786-99). Those requests
were rejected. (ROA.17788, 17794-95) (RE Tab 7). Accordingly, on March 5,
2012, Hill III filed a motion to compel the former trustees of the MHTE to make
the books and records of the trust available either to the successor trustees or to
Hill III personally, which motion was supported by declarations submitted by the

2
Hill III also filed a separate appeal in a related case (Campbell, Harrison &
Dagley, et al. v. Hill, et al., 5th Cir. Case No. 12-10417), which appeal was also
consolidated with his two appeals in this action. See Hill v. Hunt, et al., 5th Cir.
Case No. 11-10348, Order (entered J uly 25, 2012).

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successor trustees.
3
(ROA.17738-99). Hill IIIs motion to compel was joined by
the guardian-ad-litem who had been appointed by the district court to represent the
interests of Hill IIIs minor children. (ROA.Sealed, Dkt. 1281 at 2-4).
The magistrate judge who was assigned by the district court to consider Hill
IIIs motion to compel found that it is common practice for trustees to willingly
provide the trusts books and records to successor trustees in the usual
circumstances, and that [i]n all likelihood, the drafters of the MHTE trust
agreement contemplated that such books and records would naturally be given to
any successor trustees. (ROA.17980-81) (RE Tab 4). Nonetheless, the magistrate
entered an order on J anuary 15, 2013 denying Hill IIIs motion. (ROA.17982) (RE
Tab 4).
Thereafter, Hill III timely filed objections pursuant to Federal Rule of Civil
Procedure 72 seeking review of the magistrate judges ruling by the district court.
4

(ROA.Sealed, Dkt.1343). On J uly 30, 2013, J udge Solis entered his first and only
substantive order in the action, overruling all of Hill IIIs objections to the

3
The Final J udgment appointed Hill III as an Advisory Board member of the
MHTE-Hill III Trust. (ROA.Sealed, Dkt.999 at 20) (RE Tab 9). Hill III therefore
had standing to bring the motion to compel in his own right, as the MHTEs
Articles of Agreement provide that Advisory Board members have unfettered
access to the records of the trust. (ROA.17765) (RE Tab 5).
4
A party is entitled to have the district court review a magistrate judges ruling
pursuant to Rule 72. Here, however, the magistrate judges ruling at issue was
entered after the Final J udgment. Accordingly, Hill III objected to the magistrates
ruling both under Rule 72 and under Federal Rule of Civil Procedure 60(b).

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magistrates order. (ROA.18175-85) (RE Tab 3). The district court ruled that
[t]he MHTE Articles of Agreement do not provide successor trustees an absolute
right to inspect, view, see, peek at, peruse, skim, scan, gaze upon, or otherwise
examine an outgoing trustees books and records. (ROA.18181) (RE Tab 3).
Likewise, the district court ruled that the MHTE Articles of Agreement contain no
express provision which directs an outgoing trustee to confer even a single book,
record, or leaf of paper to any successor trustee. (ROA.18180) (RE Tab 3). The
district court further reasoned that even assuming the former trustees might
otherwise have had an obligation to turn over the books and records to a successor
trustee, the provision of the Settlement Agreement that released the former trustees
from providing a trust accounting effectively obviated any such requirement.
(ROA.18180-81) (RE Tab 3).
Hill III timely filed notice of this appeal from the district courts order
denying his motion to compel. (ROA.18186-87) (RE Tab 2). Approximately one
month following Hill IIIs notice of appeal, J udge Solis recused himself from the
underlying litigation without providing the parties with any explanation for his
decision to recuse. (ROA.18192).


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STANDARD OF REVIEW
The primary issue presented on this appeal is whether the district court
properly interpreted the MHTEs Articles of Agreement with respect to the
successor trustees rights to obtain copies of the archives and permanent records
of the trust. A trust instrument is interpreted as a contract, and like the
interpretation of a contract the construction of a trust instrument is a question of
law. Therefore, the interpretation of a trust instrument is reviewed de novo.
Goldin v. Bartholow, 166 F.3d 710, 715 (5th Cir. 1999).Accordingly, the
appropriate standard of review with respect to Hill IIIs appeal from the district
courts J uly 30, 2013 order is de novo.
SUMMARY OF THE ARGUMENT
This appeal raises a straightforward issue of law: Do the successor trustees
of the sub-trusts created from the MHTE pursuant to the parties Settlement
Agreement and the Final J udgment have a right to obtain copies of the archives
and permanent records of the MHTE? As a matter of logic and plain English, the
answer to that question is clearly yes. Moreover, there is no justification
whatsoever for the district courts implicit ruling that successor trustees for certain
of the sub-trusts that were created from the MHTE are entitled to complete copies
of the books and records of the MHTE, but that successor trustees for other sub-
trusts created from the MHTE (i.e., those sub-trusts of which Appellant is a

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beneficiary) are not entitled to those same records. Simply put, the district courts
ruling was erroneous as a matter of law, and should be reversed.
In the alternative, this Court should vacate the order at issue and remand Hill
IIIs motion for consideration by the new district court judge assigned to hear this
action because the district judge who decided the motion that gives rise to this
appeal was apparently operating under a conflict of interest when the order at issue
was entered. That judge recused himself, without explanation, shortly after
entering the order that is being appealed from, and the order itself is replete with
statements that are disparaging of Appellant.
ARGUMENT
I. The Successor Trustees of the Sub-Trusts Created From the MHTE Are
Entitled to Copies of the Archives and Permanent Records of the
MHTE.
A. The MHTEs Articles of Agreement Provide that a Successor
Trustee Shall Have the Same Rights as the Prior Trustee.
The May 2010 Settlement Agreement and November 2010 Final J udgment
in this action required that the MHTE be divided into separate sub-trusts for the
benefit of the then-existing beneficiaries of the trust. (See ROA.Sealed, Dkt.879 at
17; ROA.Sealed, Dkt.999 at 7-20). In connection with that division, the assets of
the MHTE were required to be divided pro rata between the sub-trusts according to
the proportional interests of the beneficiaries. (ROA.Sealed, Dkt.879 at 17;
ROA.Sealed, Dkt.999 at 7-20). The Final J udgment further required that the sub-

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trusts would continue to be governed by the MHTEs original Articles of
Agreement, with three very limited (and irrelevant, for purposes of this appeal)
exceptions. (ROA.Sealed, Dkt.999 at 24-25) (RE Tab 9). In other words, the
parties Settlement Agreement and the Final J udgment provide that the sub-trusts
are simply continuations of the MHTE, and will be treated for tax and other
reasons as though the original 1935 trust had remained intact and undisturbed.
(ROA.Sealed, Dkt.879 at 23-24 (RE Tab 10); ROA.Sealed, Dkt.999 at 7-8 (RE
Tab 9).
The MHTEs Articles of Agreement require the trustee to maintain archives
and permanent records of the trust, which records and books of account shall at
all times be open for the inspection of the other two members of the Advisory
Board.
5
(ROA.17765) (RE Tab 5). The Articles of Agreement further provide
that the trustee shall continue to serve until replaced by a successor trustee, and
that immediately upon election, the successor trustee shall step into the shoes of
the prior trustee with respect to all rights and duties, including duties relating to the
administration of the books and records of the trust. (ROA.17761 (Article I,
Section 2 noting that his successor shall succeed to the same rights and powers
and be subject to the same duties . . . as his predecessor.)) (RE Tab 5).

5
The Articles of Agreement provide that the MHTE shall have a three-member
Advisory Board, consisting of the Trustee and two other members.
(ROA.17765) (RE Tab 5).

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Notwithstanding the clear and unambiguous language cited above, the
district court ruled that the successor trustees of the two MHTE sub-trusts for
which Hill III is either a current or future beneficiary are not entitled to obtain
copies of the archives and permanent records of the MHTE from the predecessor
trustees. The district court reasoned that (a) the MHTEs Articles of Agreement do
not specifically mention a former trustee delivering the records of the trust to a
successor trustee, and (b) the successor trustees duty with respect to trust records
is purportedly limited to maintaining permanent records henceforth i.e.,
commencing after the successor trustee is appointed. (ROA.17980-81, 18180) (RE
Tabs 3 & 4).
Respectfully, the district courts ruling is flatly inconsistent with the Articles
of Agreement, Texas law, and common sense. As noted above, the Articles of
Agreement require the trustee to maintain archives and permanent records of the
trust. (ROA.17765) (RE Tab 5). The terms archives
6
and permanent
7
are

6
For example, the Merriam-Webster Dictionary defines an archive as a place in
which public records or historical materials (such as documents) are kept.
Merriam Webster Dictionary, http://www.merriam-webster.com/dictionary/archive
(emphasis added). Likewise, the American Heritage Dictionary defines an
archive as [a] place or collection containing records, documents, or other
materials of historical interest.
http://ahdictionary.com/word/search.html?q=archive. Similarly, the Oxford
Dictionary defines archive as a collection of historical documents or records
providing information about a place, institution, or group of people. Oxford
Dictionaries,
http://www.oxforddictionaries.com/us/definition/english/archive?q=archive.

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commonly used words with well-established definitions. Applying those well-
established definitions, the plain language of the Articles of Agreement requires
the acting trustee which would include any successor trustee to maintain
permanent, historical records of the trust, which records must at all times be open
for the inspection of the trusts three-member Advisory Board. (ROA.17765) (RE
Tab 5). The successor trustees duty to maintain and make available for inspection
the archives and permanent records commences immediately upon the
successor trustee being elected. (ROA.17761) (RE Tab 5).
The Articles of Agreement are equally clear that the archives and
permanent records belong to the trust, not to the trustee. Indeed, that is expressly
what Article I, Section 10 of the Articles of Agreement provides when it requires
the acting trustee to have the books and records of the trust audited annually, and
have the report or said audit filed as part of the archives and permanent records of
said Trust Estate. (ROA.17765) (RE Tab 5).

7
The Merriam Webster Dictionary defines permanent as lasting or continuing
for a very long time or forever; not temporary or changing. Merriam Webster
Dictionary, http://www.merriam-webster.com/dictionary/permanent. The
American Heritage Dictionary defines permanent as [l]asting or remaining
without essential change. American Heritage Dictionary, http://ahdictionary.com/
word/search.html?q=permanent. The Oxford Dictionary defines permanent as
lasting or intended to last or remain unchanged indefinitely. Oxford
Dictionaries,
http://www.oxforddictionaries.com/us/definition/english/permanent?q=permanent.

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Nothing in the Articles of Agreement suggests, or could be read to imply,
that when a successor trustee is elected, the archives and permanent records of
the trust shall be abandoned, and that the successor trustee shall only maintain
records henceforth. Indeed, the term henceforth does not appear anywhere in
the relevant provisions of the Articles of Agreement the district court simply
inserted this limitation of its own accord. (ROA.17980-81, 18180) (RE Tabs 3 &
4).
Equally importantly, nothing in the Articles of Agreement or in the parties
Settlement Agreement supports the conclusion that successor trustees for certain of
the sub-trusts created from the MHTE shall have access to the permanent records
of the trust, but that successor trustees for other sub-trusts shall be denied access.
But that is exactly the unwarranted and unprecedented dichotomy that the district
court created by ruling that the successor trustees for the two sub-trusts of which
Hill III is a current or remainder beneficiary are not entitled to copies of the
MHTEs records since it is undisputed that successor trustees for other sub-trusts
created under the Final J udgment do have those very materials. (ROA.Sealed,
Dkt.1359 at 7; see also ROA.Sealed, Dkt.1288 at 8 n.6). Both the trust agreement
itself and basic fairness dictate that the successor trustees for the sub-trusts
affiliated with Hill III must be given the same access to the records of the trust as
the successor trustees for the other sub-trusts created from the MHTE.

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B. Texas Law Is Fully Consistent with the MHTEs Articles of
Agreement with Respect to the Successor Trustees Rights.
The conclusion that a successor trustee is entitled to copies of the historical
records of the MHTE is not only clear from the Articles of Agreement, but is also
amply supported by the Texas laws that the district court relied upon in creating
the sub-trusts. (See ROA.Sealed, Dkt.999 at 7) (RE Tab 9). For example, Texas
Property Code section 112.057 permits a trustee to divide a trust only if the terms
of the separate trusts [are] identical to the terms of the original trust. Likewise,
Texas Property Code section 112.054 permits a judicial modification of an
existing trust provided that it conforms as nearly as possible to the probable
intention of the settlor. Consistent with these statutory provisions, the Final
J udgment makes clear that the sub-trusts are simply proportionate divisions of the
existing trust estate governed, with very limited exceptions, by the original 1935
Articles of Agreement. (See ROA.Sealed, Dkt.999 at 7-20, 24-25). In other
words, the sub-trusts constitute a continuation, not a termination, of the MHTE.
Moreover, as with the Articles of Agreement, the Texas Property Code
provides that a successor trustee has the same rights, powers, authority, discretion,
and title to trust property as was conferred on the prior trustee. Tex. Prop. Code
113.084. Simply put, under Texas law, a successor trustee steps into the shoes of
the former trustee. Thus, if the former trustee had access to the archives and

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permanent records of the MHTE, the successor trustee must have the same right to
access those archives and permanent records.
The district court faulted Hill III for failing to cite any Texas case in which a
predecessor trustee was ordered to turn over the books and records of the trust to a
successor trustee. (ROA.18182) (RE Tab 3). However, it is unsurprising that Hill
III was unable to locate any such case given that, as the magistrate judge
acknowledged, the turnover of the trusts records to the successor trustee would be
expected to happen as a matter of course. (ROA.17980) (RE Tab 4). Hill III
respectfully submits that it is far more significant that there is no Texas authority
that supports the district courts troubling conclusions that (a) a prior trustee has no
obligation to provide the trusts books and records to a successor trustee, and (b)
when a trust is divided into separate sub-trusts, successor trustees for some sub-
trusts but not others are entitled to copies of the trusts records. Given the lack of
any Texas state court cases supporting the obviously flawed conclusions reached
by the district court, this Court would be setting a perilous and unfortunate
precedent if it were to affirm the district courts ruling.
C. Hill III Presented Undisputed Evidence that the Successor
Trustees Have a Legitimate Need to Access the Permanent
Records of the MHTE.
As discussed above, the plain language of the MHTEs Articles of
Agreement require the trustee (including a successor trustee) to maintain historical

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records of the trust. This requirement makes perfect sense. The MHTE was
established in 1935 and was written to continue until the Death of Margaret
Hunt . . . and for twenty-one years after . . . her death that is, the trust was
intended to last (and has lasted) for decades. (ROA.17767-68) (RE Tab 5).
Maintaining permanent trust records throughout the life of the trust would
therefore be important, if not essential, to simply by way of example establish
the trusts tax basis in property acquired over time, and to keep track of the trusts
various different investments and their performance.
8

Nothing in either the Articles of Agreement, the Final J udgment, or Texas
law requires the successor trustees, or Hill III personally, to make any showing of
need in order for the successor trustees to obtain access to the records of the
MHTE. Nonetheless, Hill III and the successor trustees presented largely
uncontested evidence to the district court that the successor trustees ability to
effectively administer the sub-trusts is being hampered by their lack of access to
the permanent records of the MHTE. (ROA.17786-99). For example, the
successor trustees testified by declaration that they would not be able to
definitively ascertain the tax basis for a significant portion of the assets of the sub-

8
The magistrate judge who initially denied Hill IIIs original motion
acknowledged that the original intent of the drafter of MHTEs Articles of
Agreement was likely to provide copies of the books and records to the successor
trustee. (ROA.17980 (In all likelihood, the drafters of the MHTE trust agreement
contemplated that such records and books would naturally be given to any
successor trustees.)) (RE Tab 4).

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trusts at issue namely, the MHTEs ownership of Exxon Mobil securities
without access to the MHTEs historical books and records.
9
(ROA.17788, 17795)
(RE Tab 7).
Separately and additionally, Hill III submitted evidence showing that having
access to the permanent records of the trust was critical in order for the successor
trustees, and for Hill III personally, to ascertain whether the sub-trusts had been
correctly funded as required by the Settlement Agreement and Final J udgment. In
this regard, Hill III offered uncontested evidence that in connection with dividing
certain illiquid assets among the sub-trusts as required by the Final J udgment, the
former trustees had failed to disclose certain assets that Hill III had subsequently
managed to locate himself by reference to secondary sources such as public
records. (ROA.17756) (RE Tab 6). Confronted with the secondary evidence
unearthed by Hill III, the former trustees later admitted that certain of the
information they had provided about the assets that were being divided among the

9
The district court found that the successor trustees concerns on this point are
unfounded because the prior trustees had produced a single document, prepared by
a non-party, purporting to state the MHTEs tax basis in the Exxon securities.
(ROA.18181) (RE Tab 3). However, the successor trustees were aware of the
document referenced by the district court when they testified that additional
information was needed in order to definitively ascertain the tax basis of assets
valued in the tens of millions of dollars. (ROA.17790, 17797). Accordingly, the
district courts finding on this issue was not supported by the record, and is clearly
erroneous.

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sub-trusts had been inaccurate. (ROA.Sealed, Dkt.1207 at 2, 4-8; ROA.Sealed,
Dkt.1215 at 2, 4-8).
Simply put, access to the archives and permanent records of the MHTE is
important, and likely essential, in order for the successor trustees to properly carry
out their obligations with respect to the sub-trusts. (ROA.17786-88, 17794-95)
(RE Tab 7). In this regard, the case of Hoenig v. Texas Commerce Bank, N.A. is
instructive. 939 S.W.2d 656 (Tex. App. San Antonio 1996, no writ). In that
case, a successor trustee obtained the records of the trust from the outgoing trustee,
and subsequently determined from those records that the prior trustee had
negligently failed to collect rents for more than ten years on properties owned by
the trust. Id. at 658-59. Ironically, the former trustee then contended that the
successor trustee should be held jointly liable to the beneficiary on the theory that
the successor trustee should have immediately spotted the error. The court rejected
this theory for various reasons, including that the successor trustee had promptly
spotted and taken steps to address the issue. Id. at 662-63. Hoenig is illustrative
both of the fact that a successor trustee necessarily has access to the records of the
trust, and also of the reasons why a successor trustees access to trust records is
vitally important.

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In short, here the record more than amply shows that the successor trustees
of the sub-trusts created from the MHTE have a legitimate need for access to the
permanent records of the trust.
D. The Prior Trustees Are Not Being Asked to Provide a Trust
Accounting.
In its order denying Hill IIIs motion to compel, the district court reasoned
that even if the successor trustees would otherwise be entitled to the records of the
MHTE, here Hill III has supposedly waived any right to obtain those records
because he agreed in the Settlement Agreement to release the prior trustees for any
claim relating to failure to furnish any trust accounting for either of the MHTE or
the HHTE, for time periods before and including the resignation dates of the
trustees and advisory board members. (ROA.18182 (citing ROA.Sealed, Dkt.999
at 26); ROA.Sealed, Dkt.879 at 25 (emphasis added)) (RE Tabs 3, 9 & 10).
The issue before the district court on Hill IIIs motion to compel, and the
issue before the Court on this appeal, is not whether the former trustees should be
required to provide a trust accounting, since neither Hill III nor the successor
trustees are seeking a trust accounting. Rather, the issue before this Court is
whether the successor trustees should be permitted to copy the archives and
permanent records of the MHTE.
A trust accounting is defined under the Texas Property Code as a specific
written statement of accounts encompassing five distinct categories of

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information, which must be generated and delivered by a trustee in response to a
beneficiarys demand. See Tex. Prop. Code 113.151, 113.152. Thus, a
beneficiarys right to a trust accounting is defined by law, and is entirely distinct
from a successor trustees right under the MHTEs Articles of Agreement to obtain
the existing archives and permanent records of the trust. In this regard, the
portion of the Settlement Agreement cited by the district court does not state or
imply that the successor trustee is somehow precluded from obtaining the existing
records of the trust, nor was such a result ever intended by the parties.
10

In concluding that Hill IIIs motion to compel was foreclosed by the
Settlement Agreement, J udge Solis also incorrectly concluded that J udge
OConnors March 4, 2011 order denying Hill IIIs motion to alter or amend the
Final J udgment (ROA.Sealed, Dkt.1099 at 11 (RE Tab 8)) otherwise provided . . .
by order of the court that the successor trustees should not be permitted to access,
inspect, and copy the MHTE books and records. (ROA.18182-82) (RE Tab 3).
This conclusion wholly misconstrues the prior order.

10
At a May 12, 2010 conference concerning the Settlement Agreement, Frank
Ikard, then-counsel for Appellee Lyda Hill, discussed the provision of the
Settlement Agreement cited by the district court, explaining that [t]his is standard
language to get a successor corporate trustee, you have to have an agreement
because a successor trustee has to go back and investigate everything that a prior
trustee did and so no one is going to serve as a successor trustee with all these
allegations unless this language is in the instrument. (ROA.Sealed, Dkt.1267-1 at
223-24).

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As discussed above, soon after the Final J udgment was entered in November
2010, Hill III filed a motion to alter or amend the judgment in which he argued that
due to the passage of time between the Settlement Agreement and the Final
J udgment, the district court should order that Hill III, as a beneficiary of the
MHTE, had a right to a complete, updated accounting and right of inspection as to
the MHTE. (ROA.Sealed, Dkt.1050 at 14). The district court denied Hill IIIs
motion to alter or amend, finding that there was no basis to add a provision to the
Final J udgment entitling Hill III to an updated accounting in light of the language
in the Settlement Agreement providing that the former trustees were absolved from
liability for failure to furnish any trust accounting. (ROA.Sealed, Dkt.1099 at
11) (RE Tab 8).
Whether or not the district courts ruling on Hill IIIs motion to alter or
amend was correct, that ruling involved a totally separate issue than the one
presented here. Specifically, the motion to alter or amend raised the issue of
whether Hill III, in his capacity as a beneficiary, was entitled to an updated
accounting because of the passage of approximately six months between the
settlement and the entry of judgment. By contrast, the issue raised here is whether
the successor trustees are entitled to copies of the archives and permanent
records of the trust.

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In concluding that J udge OConnors prior order had addressed this issue,
J udge Solis incorrectly treated the successor trustees as if they are merely agents of
Hill III. They are not. To the contrary, a trustee is the owner of the legal title to
the trust corpus and the administrator of the trust, with a set of established rights
and obligations that are separate and distinct from the rights and obligations of the
beneficiary. (See ROA.17761-67) (RE Tab 5). Accordingly, the fact that the prior
district court judge found that Hill III was not entitled to a post-settlement
accounting in his role as a beneficiary is not relevant to the question of whether the
successor trustees are entitled to copies of the archives and permanent records of
the trust.
E. The Other Objections Raised by Appellees Lack Merit.
In their briefing before the district court, Appellees raised various additional
objections to Hill IIIs motion to compel the MHTEs records to be produced to the
successor trustees. None of those objections is meritorious. For example, the
former trustees objected that they should not be required to transfer the trusts
records to the successor trustees. However, Hill IIIs motion did not seek to
compel the transfer of the records rather, it sought merely to obtain copies of
the records for the successor trustees, and the successor trustees offered to pay for
those copies. (ROA.17743-44).

2953072
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The former trustees also argued that Hill III has already received voluminous
document productions during the course of the underlying litigation, and that those
records should be deemed sufficient. (ROA.Sealed, Dkt.1266 at 12-13). However,
the former trustees offered no evidence supporting the conclusion that the trust
records produced to Hill III during the litigation constitute the complete archives
and permanent records of the MHTE. The fact that some trust records were
previously produced to Hill III is irrelevant.
The former trustees likewise argued to the district court that production of
the MHTEs books and records would require substantial time and expense,
including a privilege review and withholding of particular documents based on a
discovery agreement with a third party. (ROA.Sealed, Dkt.1350 at 12 n.6). These
arguments are specious. As noted above, the successor trustees offered to pay for
making copies of the trust records, so the prior trustees faced no copying expenses
whatsoever. (ROA.Sealed, Dkt.1343 at 8-9 n.6; ROA.17790 (RE Tab 7)).
Moreover, there is no legitimate need for the prior trustees to conduct a privilege
review with respect to the archives and permanent records of the trust, since the
successor trustees are in legal privity with the former trustee. See In re Bradley,
501 F.3d 421, 433 (5th Cir. 2007) (citing Huie v. DeShazo, 922 S.W.2d 920, 926
(Tex. 1996) (an attorney represents the trustee in his capacity as trustee)); see
also Interfirst Bank-Houston, N.A. v. Quintana Petroleum Corp., 699 S.W.2d 864,

2953072
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879 (Tex. App. Houston [1st Dist.] 1985) (a successor trustee is in privity with
their predecessors as trustees, with respect to legal claims or rights that may be
asserted). Thus, even assuming for the sake of argument that the permanent
records of the trust contain privileged materials, the successor trustee not the
former trustee is now the holder of that privilege.
Simply put, Appellees have never articulated any objection to the production
of the MHTEs records to the successor trustees that is sufficient to outweigh the
successor trustees fundamental right to access those materials.
II. At a Minimum, Judge Soliss July 30, 2013 Order Should Be Vacated or
Remanded to the District Court, Because He Was Apparently
Operating under an Undisclosed Conflict.
This case was assigned to J udge Solis on May 23, 2013. Two months later,
on J uly 30, 2013, J udge Solis entered his one and only substantive ruling in this
action, which is the order at issue on this appeal. (ROA.18175-85) (RE Tab 3). In
addition to being erroneous for the reasons discussed above, J udge Soliss order is
also loaded with intemperate language and disparaging descriptions of both Hill III
personally (who is accused of, e.g., tilt[ing] at yet another windmill) and the
legal positions advanced by Hill III and his counsel (e.g., Nothing in the express
language of the MHTE Articles of Agreement directs a trustee to confer the
permanent records of the MHTE to successor trustees as though it were the family

2953072
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Bible, handed down from generation to generation.). (See ROA.18176-77,
18180-81) (RE Tab 3).
Hill III timely appealed J udge Soliss ruling, and then on September 26,
2013, less than two months after entering his solitary substantive ruling J udge
Solis voluntarily recused himself without explanation. (ROA.18192).
The United States Supreme Court has held that when a district court recuses
itself after entering one or more substantive orders, an appropriate remedy under
certain circumstances is to vacate any orders and judgments entered after the point
when the court should have recused itself. See Liljeberg v. Health Servs.
Acquisition Corp., 486 U.S. 847, 864 (1988) (listing factors to be considered,
including: (1) the risk of injustice to the parties in the particular case, (2) the risk
that the denial of relief will produce injustice in other cases, and (3) the risk of
undermining the publics confidence in the judicial process).
In this action, between the time that J udge Solis was appointed to hear the
matter on May 23, 2013, and the time that J udge Solis recused himself on
September 26, 2013, no new parties or causes of action were added. It is therefore
highly probable, if not certain, that whatever conflict caused J udge Solis to recuse
himself existed at the time he was appointed, and at the time he entered the order
that is being appealed from. There is a high risk of injustice to the parties and
specifically to Hill III as well as a risk of undermining the publics confidence in

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the judicial process, when a judge who was apparently operating under a conflict
renders an important order that disparages ones party and then promptly recuses
himself thereafter.
Rohrbach v. AT&T Nassau Metals Corp. is instructive. 915 F. Supp. 712
(M.D. Pa. 1996). In that case, the district judge recused himself after presiding
over a case for four years and after entering a number of substantive rulings. In
order to minimize the risk of injustice in that case, the new district court judge
fashioned an appropriate remedy independently reviewing every prior ruling for
bias to address the undisclosed conflict. Id. at 717.
Here, if J udge Soliss one and only substantive order is reviewed for bias,
the order cannot withstand scrutiny indeed, seldom does a district court judge,
and particularly one that has only presided over a matter for a short period, enter
such a vitriolic and disparaging order against a party. Accordingly, at a minimum,
J udge Soliss order should be vacated, and Hill IIIs original motion to compel
should be remanded for consideration by the new district judge who has been
assigned to this action.
CONCLUSION
Under the MHTEs Articles of Agreement and Texas law, the successor
trustees of the sub-trusts created pursuant to the parties Settlement Agreement are
entitled to copies of the archives and permanent records of the MHTE.

2953072
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Accordingly, the district courts order denying Hill IIIs motion to compel should
be reversed. In the alternative, in light of the district court judges subsequent and
unexplained recusal, this Court should vacate the order at issue and remand Hill
IIIs motion to compel for consideration by the new district court judge assigned to
this action.

Respectfully submitted,

/s/ Iian D. Jablon (w/p AKW)
Iian D. J ablon
Aarti K. Wilson
Irell & Manella LLP
Suite 900
[Tel.] (310) 277-1010
[Fax] (310) 203-7199

ATTORNEYS FOR APPELLANT

2953072
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CERTIFICATE OF COMPLIANCE
1. This brief complies with the type-volume limitations of Federal Rule
of Appellate Procedure 32(a)(7)(B) because this brief contains 7,620 words,
excluding the parts of the brief exempted by Federal Rule of Appellate Procedure
32(a)(7)(B)(iii).
2. This brief complies with the typeface requirements of Federal Rule of
Appellate Procedure 32(a)(5) and the type-style requirements of Federal Rule of
Appellate Procedure 32(a)(6) because this brief has been prepared in a
proportionally spaced typeface using Microsoft
Office Word 2010 in 14-Point

Times New Roman font.

Date: J anuary 29, 2014 /s/ Aarti K. Wilson
Aarti K. Wilson

2953072
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CERTIFICATION
1. The electronic submission is an exact copy of the paper document, 5th
Cir. R. 25.2.1; and,
2. The document has been scanned for viruses with the most recent
version of a commercial virus scanning program and is free of viruses.

Date: J anuary 29, 2014 /s/ Aarti K. Wilson
Aarti K. Wilson

2953072
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CERTIFICATE OF SERVICE
I certify that the foregoing Brief of the Appellant was filed with the Court
via the courts electronic filing system on the 29
th
day of J anuary 2014, and an
electronic copy of the Brief of the Appellant was served on all counsel of record,
as listed below, via the courts electronic filing system on the same date:
Carrie L. Huff
HAYNES & BOONE LLP
Dallas, Texas 75219

Attorneys for Defendant
William Schilling

Harry M. Reasoner
VINSON & ELKINS LLP

Attorneys for Defendant Ivan Irwin, Jr.
Michael L. Raiff
Dallas, Texas 75201

J . Keith Benedict
A G HILL PARTNERS LLC
Dallas, Texas 75201

Albert G. Hill, Jr.

Donald E. Godwin
Shawn McCaskill
Israel R. Silvas
Robert J . McGuire
W. Ira Bowman
GODWIN RONQUILLO PC
Dallas, Texas 75270

Alinda H. Wikert
IKARD GOLDEN, PC
Austin, Texas 78701

Kirk Todd Florence
J ennifer L. Graf
CROUCH & RAMEY, L.L.P.
Stephen D. Susman
SUSMAN GODFREY, LLP

Carrie L. Huff
HAYNES & BOONE, LLP

2953072
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Dallas, TX 75202
Attorneys for Defendant Lyda Hill

Dallas, Texas 75219

Attorneys for Defendants Brett Ringle
and Margaret Keliher

B. Patrick Shaw
WOODWARD & SHAW
4849 Greenville Avenue, Suite 1111
Dallas, Texas 75206

Attorney for Defendant
William Herbert Hunt

Stewart H. Thomas
Tom M. Dees, III
HALLETT & PERRIN, PC
Dallas, Texas 75201

Attorneys for Defendants
Heather V. Washburne and Elisa M.
Summers

Thomas C. Wright
Howard Louis Close
Patrick Boone McAndrew
Kathleen Sheila Rose
WRIGHT & CLOSE L.L.P.
1 Riverway, Suite 2200
Houston, TX 77056
Attorneys for Intervenor Campbell
Harrison & Dagley, L.L.P.
Thomas C. Wright
Howard Louis Close
Patrick Boone McAndrew
Kathleen Sheila Rose
WRIGHT & CLOSE L.L.P.
1 Riverway, Suite 2200
Houston, TX 77056

Attorneys for Intervenor Calloway,
Norris, Burdette & Weber, P.L.L.C

/s/ Aarti K. Wilson
Aarti K. Wilson


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