Pfizer Inc. and Tris Pharma, Inc. v. the State of Texas and Tarik Ahmed

ACCEPTED 15-25-00021-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 3/18/2025 8:50 AM No. 15-25-00021-CV CHRISTOPHER A. PRINE __________________________________________________________________ CLERK FILED IN In the Fifteenth Court of Appeals 15th COURT OF APPEALS Austin, Texas AUSTIN, TEXAS 3/18/2025 8:50:42 AM __________________________________________________________________ CHRISTOPHER A. PRINE Clerk PFIZER INC. and TRIS PHARMA, INC., Petitioners/Defendants, v. The STATE OF TEXAS and TARIK AHMED, Respondents/Plaintiffs. __________________________________________________________________ Permissive appeal from the 71st Judicial District Court, Harrison County, Texas

UNOPPOSED MOTION OF NON-RESIDENT ATTORNEY STEFAN P. SCHROPP FOR ADMISSION PRO HAC VICE __________________________________________________________________ Edward D. Burbach (No. 03355250) Samantha Barrett Badlam Stacy R. Obenhaus (No. 15161570) (Pro hac pending) Congress, Suite 2900 Stefan P. Schropp Austin, Texas 78701 (Pro hac pending) [email protected] 2099 Pennsylvania Ave., N.W. [email protected] Washington, D.C. 20006-6807 Tel: 512.542.7070 [email protected] George Valton (“Val”) Jones [email protected] (No. 10888050) Tel: 202.508.4734 West Austin St. Marshall, Texas 75670-3340 Counsel for Pfizer Inc. [email protected] Tel: 903.927.2220 TO THE HONORABLE JUDGE OF THE COURT: I, Stefan P. Schropp, move this Court for permission to appear before the Court Pro Hac Vice, under the authority of the Rules Governing Admission to the Bar of Texas, Rule XIX, as attorney for Petitioner/Defendant Pfizer Inc. (“Pfizer”), and would show the Court the following: BACKGROUND 1. My contact information is as follows: Stefan P. Schropp ROPES & GRAY LLP 2099 Pennsylvania Ave., N.W. Washington, DC 20006-6807 [email protected] (202) 508-4734

2. I am associated with Edward D. Burbach, who will personally participate in the appeal of this case on behalf of Pfizer. Mr. Burbach is a partner and practicing attorney at Foley & Lardner LLP and a member of the State Bar of Texas. His State Bar number and contact information is as follows: Edward D. (“Ed”) Burbach Texas State Bar No. 03355250 FOLEY & LARDNER LLP Congress Avenue, Suite 2900 Austin, Texas 78701 [email protected] PH: (512) 542-7070 3. Mr. Burbach’s Motion in Support of this Motion for Admission Pro Hac Vice is being filed separately.

1. I am an active member in good standing with the District of Columbia Bar, at Bar No. 1026864 (admitted November 3, 2017) with the Maryland Bar at Bar No. 1702130002 (admitted in February 2017), the U.S. Supreme Court, the U.S. Court of Appeals for the 4th Circuit, the U.S. Court of Appeals for the 9th Circuit, the U.S. Court of Appeals for the 11th Circuit, the U.S. District Court for the District of Maryland, and the U.S. District Court for the Middle District of Georgia. A certificate of good standing from the District of Columbia is attached hereto as Exhibit A.

2. I have not been the subject of any disciplinary action in the last five years by the Bar or courts of any jurisdiction in which I have been licensed.

3. I have not been denied admission to the courts of any State or to any federal court during the preceding five years.

4. I am familiar with the State Bar Act, the State Bar Rules, and the Texas Disciplinary Rules of Professional Conduct governing the conduct of members of the Bar and will at all times abide and comply with the same.

5. I have previously appeared in the following cases or causes in Texas courts within the past two years: The State of Texas, ex rel. Tarik Ahmed, Plaintiffs v. Pfizer Inc., Tris Pharma, Inc., and Ketan Mehta, Cause No. 23-1031, In the District Court, Harrison County, Texas 71st Judicial District.

6. I have paid the nonresident attorney fee required by Section 82.0361(b) of the Texas Government Code. A copy of the March 5, 2025 Acknowledgment Letter from the Board of Law Examiners acknowledging receipt of my Application for Pro Hac Vice Admission and payment of the required fee is attached hereto as Exhibit B.

PRAYER For the reasons stated above, I respectfully ask the Court to grant my Unopposed Motion for Pro Hac Vice Admission and allow me to appear in all proceedings before this Court until the conclusion of this case.

Respectfully submitted,

ROPES & GRAY LLP By:/s/ Stefan P. Schropp Stefan P. Schropp (application for pro hac admission pending) 2099 Pennsylvania Ave., N.W. Washington, DC 20006-6807 [email protected] (202) 508-4734 Counsel for Pfizer Inc. DECLARATION My name is Stefan P. Schropp, my date of birth is February 22, 1987, and my business address is 2099 Pennsylvania Avenue, N.W., Washington, District of Columbia 20006-6807. I declare under penalty of perjury that the foregoing is true and correct.

/s/ Stefan P. Schropp Stefan P. Schropp CERTIFICATE OF CONFERENCE Under Texas Rule of Appellate Procedure 10.1(5), I certify that on March 14, 2025, I conferred with Appellants’ counsel about the relief requested in this motion. Appellants’ counsel responded that Appellants are unopposed.

/s/ Stefan P. Schropp Stefan P. Schropp CERTIFICATE OF SERVICE I hereby certify that on this 17th day of March, 2025, a true and correct copy of the foregoing Unopposed Motion of Non-Resident Attorney Stefan P. Schropp for Admission to Appear Pro Hac Vice was served on the following counsel of record by electronic service pursuant to Texas Rule of Appellate Procedure 9.5 or as otherwise indicated below: COUNSEL FOR THE STATE OF BROWN, LLC TEXAS Jason T. Brown Jonathan Bonilla [email protected] Jordan Underhill Patrick S. Almonrode Vivian Egbu [email protected] Brittany Peters 111 Town Square Place, Suite 400 Office of the Attorney General, Civil Jersey City, NJ 07310 Medicaid Fraud Division (877) 561-0000 P.O. Box 12548, Capitol Station Austin, TX 78711-2548 POTTER MINTON, P.C. [email protected] Michael E. Jones [email protected] [email protected] [email protected] E. Glenn Thames, Jr. [email protected] [email protected] (512) 475-4169 102 North College, Suite 900 Tyler, TX 75702 (903) 597-8311

/s/ Stefan P. Schropp Stefan P. Schropp EXHIBIT A On behalf of JULIO A. CASTILLO, Clerk of the District of Columbia Court of Appeals, the District of Columbia Bar does hereby certify that

Stefan Parker Schropp was duly qualified and admitted on November 3, 2017 as an attorney and counselor entitled to practice before this Court; and is, on the date indicated below, an Active member in good standing of this Bar.

In Testimony Whereof, I have hereunto subscribed my name and affixed the seal of this Court at the City of Washington, D.C., on March 07, 2025.

JULIO A. CASTILLO Clerk of the Court

Issued By:

David Chu - Director, Membership District of Columbia Bar Membership

For questions or concerns, please contact the D.C. Bar Membership Office at 202-626-3475 or email [email protected].

EXHIBIT B Board of Law Examiners Appointed by the Supreme Court of Texas March 05, 2025

Stefan Schropp Via: E-Mail

Acknowledgment Letter Non-Resident Attorney Fee According to Texas Government Code §82.0361, "a nonresident attorney requesting permission to participate in proceedings in a court in this state shall pay a fee of $250 for each case in which the attorney is requesting to participate." This Acknowledgement Letter serves as proof that the Board of Law Examiners has received $250 in connection with the following matter: Non-resident attorney: Stefan Schropp Case: 15-25-00021-CV Texas court or body: Fifteenth Court of Appeals

After satisfying the fee requirement, a non-resident attorney shall file a motion in the Texas court or body in which the non-resident attorney is requesting permission to appear. The motion shall contain the information and statements required by Rule 19(a) of the Rules Governing Admission to the Bar of Texas. The motion must be accompanied by this Acknowledgment Letter and by a motion from a resident practicing Texas attorney that contains the statements required by Rule 19(b).

The decision to grant or deny a non-resident attorney's motion for permission to participate in the proceedings in a particular cause is made by the Texas court or body in which it is filed.

For more information, please see Rule 19 of the Rules Governing Admission to the Bar of Texas and §82.0361, of the Texas Government Code, which can be found on the Board's website.

MAILING ADDRESS TELEPHONE: 512- 463-1621 - FACSIMILE: 512- 463-5300 STREET ADDRESS Post Office Box 13486 WEBSITE: www.ble.texas.gov 205 West 14th Street, Ste.500 Austin,Texas 78711-3486 Austin, Texas 78701 Automated Certificate of eService This automated certificate of service was created by the efiling system.

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

Paul Lang on behalf of Edward Burbach Bar No. 3355250 [email protected] Envelope ID: 98564310 Filing Code Description: Motion Filing Description: Unopposed Motion of Non-Resident Attorney Stefan P. Schropp for Admission Pro Hac Vice Status as of 3/18/2025 9:01 AM CST Associated Case Party: Pfizer Inc. Name BarNumber Email TimestampSubmitted Status Stacy Obenhaus [email protected] 3/18/2025 8:50:42 AM SENT Kristin Hernandez [email protected] 3/18/2025 8:50:42 AM SENT Stefan Schropp [email protected] 3/18/2025 8:50:42 AM SENT Samantha BarrettBadlam [email protected] 3/18/2025 8:50:42 AM SENT Edward Burbach [email protected] 3/18/2025 8:50:42 AM SENT George Valton [email protected] 3/18/2025 8:50:42 AM SENT

Associated Case Party: Tris Pharma Inc. Name BarNumber Email TimestampSubmitted Status Harry Gillam 7921800 [email protected] 3/18/2025 8:50:42 AM SENT Andrew Gorham 24012715 [email protected] 3/18/2025 8:50:42 AM SENT William E.Lawler, III [email protected] 3/18/2025 8:50:42 AM SENT Bobbye Pyke [email protected] 3/18/2025 8:50:42 AM SENT Huaou Yan [email protected] 3/18/2025 8:50:42 AM SENT

Associated Case Party: The State of Texas Name BarNumber Email TimestampSubmitted Status Jonathan Bonilla 24073939 [email protected] 3/18/2025 8:50:42 AM SENT Jordan Underhill 24102586 [email protected] 3/18/2025 8:50:42 AM SENT Nadia Burns 24041176 [email protected] 3/18/2025 8:50:42 AM SENT Vivian Egbu [email protected] 3/18/2025 8:50:42 AM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system.

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

Paul Lang on behalf of Edward Burbach Bar No. 3355250 [email protected] Envelope ID: 98564310 Filing Code Description: Motion Filing Description: Unopposed Motion of Non-Resident Attorney Stefan P. Schropp for Admission Pro Hac Vice Status as of 3/18/2025 9:01 AM CST Associated Case Party: Tarik Ahmed Name BarNumber Email TimestampSubmitted Status Earl Thames 785097 [email protected] 3/18/2025 8:50:42 AM SENT Jason T.Brown [email protected] 3/18/2025 8:50:42 AM SENT Patrick S.Almonrode [email protected] 3/18/2025 8:50:42 AM SENT Michael E.Jones [email protected] 3/18/2025 8:50:42 AM SENT