Red Roof Inns, Inc.; Red Roof Franchising, LLC; Sandra Wunderlich; And Stephanie Rzepka v. Jane Doe, as Parent and Next Friend of Jane Doe, a Minor; Sai Lodging, Inc., D/B/A Red Roof Inn; Batesville Lodging Group, Inc.; Rajendra Patel; Roshni Patel; John Does 1-4; And John Doe Entities 1-2
── Red Roof Inns, Inc.; Red Roof Franchising, LLC; Sandra Wunderlich; And Stephanie Rzepka v. Jane Doe, as Parent and Next Friend of Jane Doe, a Minor; Sai Lodging, Inc., D/B/A Red Roof Inn; Batesville Lodging Group, Inc.; Rajendra Patel; Roshni Patel; John Does 1-4; And John Doe Entities 1-2 ──
Court: Supreme Court of Arkansas
Date: March 12, 2026
Category: General
Cite as 2026 Ark. 50
SUPREME COURT OF ARKANSAS
No. CV-25-569
Opinion Delivered: March 12, 2026
RED ROOF INNS, INC.; RED ROOF
FRANCHISING, LLC; SANDRA
WUNDERLICH; AND STEPHANIE APPEAL FROM THE PULASKI
RZEPKA COUNTY CIRCUIT COURT
APPELLANTS [NO. 60CV-24-1541]
V. HONORABLE TIMOTHY DAVIS
FOX, JUDGE
JANE DOE, AS PARENT AND NEXT
FRIEND OF JANE DOE, A MINOR;
SAI LODGING, INC., D/B/A RED REVERSED AND REMANDED.
ROOF INN; BATESVILLE LODGING
GROUP, INC.; RAJENDRA PATEL;
AND ROSHNI PATEL; JOHN DOES
1–4; AND JOHN DOE ENTITIES 1–2
APPELLEES
KAREN R. BAKER, Chief Justice
Appellants Red Roof Inns, Inc., and Red Roof Franchising, LLC (“RRI”), filed this
interlocutory appeal from the Pulaski County Circuit Court’s orders denying out-of-state
attorneys’ pro hac vice petitions and subsequent motions for reconsideration. On appeal,
RRI argues that the circuit court erred and abused its discretion in denying attorneys
Stephanie A. Rzepka and Sandra J. Wunderlich pro hac vice admission. Appellees did not
file a responsive brief. We reverse and remand for further proceedings consistent with this
opinion.
On February 21, 2024, appellee Jane Doe filed the underlying complaint in the
Pulaski County Circuit Court alleging sex trafficking of a minor at a Red Roof Inn located
in North Little Rock, Arkansas. On May 30, 2025, Jane Doe filed her second amended
complaint adding Red Roof Inns, Inc., and Red Roof Franchising, LLC, as defendants. On
July 11, RRI filed its answer and cross-claim, which was signed solely by Arkansas counsel
Jane A. Kim of Wright, Lindsey & Jennings LLP. In addition, the pleading listed three out-
of-state attorneys with the firm Tucker Ellis LLP, including Rzepka and Wunderlich. 1 The
out-of-state attorneys did not sign the pleading and there is a notation after each name
clearly stating “(motion for pro hac vice admission forthcoming).”
On July 29, RRI filed pro hac vice petitions for Rzepka and Wunderlich. Attached
to the petitions were the affidavits of the attorneys seeking admission, proofs of payment of
the nonresident attorney fee, and affidavits of Arkansas counsel, Jane Kim. On August 6,
the circuit court denied both petitions, reasoning that the nonresident attorneys “appeared
on pleadings prior to filing the above petition to appear pro hac.”
On August 15, RRI filed a motion for reconsideration along with briefing and an
affidavit. RRI explained that, in 2023, RRI retained the law firm of Tucker Ellis LLP, and
specifically, Wunderlich, to serve as national coordinating counsel in defense of sex-
trafficking litigation filed in multiple jurisdictions.2 RRI stated that Wunderlich “developed
a deep knowledge of [RRI], their corporate structure and history, their employees, potential
witnesses, as well as sources of documents and information.” RRI explained that it utilized
the national counsel role to maintain consistency and efficiency across the litigation based
1
Chelsea Mikula was one of the three out-of-state attorneys listed, but a petition for
pro hac vice for Mikula has not been filed.
2
RRI noted that while not lead counsel, Rzepka is also an important part of the team
representing RRI.
2
on counsel’s preexisting knowledge base. Tucker Ellis LLP, recognizing the need for local
counsel to advise on the rules and procedures particular to Arkansas law, contacted Jane Kim
to serve as local counsel. RRI explained that Kim is the only attorney of record for RRI
and has been the signatory on all pleadings. Kim included Rzepka’s and Wund
{# E23 (Nick, ruling section 1 answer 10): quoting a bill or a court opinion works
the way quoting a news article works. Select a passage above and the same panel
opens: the passage goes to the official you choose, with this document's own
address as its source and its own type. #}