In Re Novartis Pharmaceuticals Corporation v. the State of Texas
In Re Novartis Pharmaceuticals Corporation v. the State of Texas
Opinion
ACCEPTED 15-25-00207-CV No. 15-25-00207-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 11/26/2025 12:33 PM IN THE CHRISTOPHER A. PRINE CLERK Court of Appeals for the FILED IN 15th COURT OF APPEALS 15th District of Texas AUSTIN, TEXAS 11/26/2025 12:33:06 PM CHRISTOPHER A. PRINE Clerk
IN RE NOVARTIS PHARMACEUTICALS CORPORATION, Relator.
_______________________________ ORIGINAL PROCEEDING FROM THE 71ST DISTRICT COURT, IN HARRISON COUNTY, TEXAS • CAUSE NO. 23-0276, THE HONORABLE BRAD MORIN PRESIDING MOTION OF NONRESIDENT ATTORNEY, ROSS B. GALIN, FOR ADMISSION PRO HAC VICE DANNY S. ASHBY ANTON METLITSKY (Texas Bar No. 01370960) ROSS B. GALIN O’MELVENY & MYERS LLP O’MELVENY & MYERS LLP 2801 N. Harwood Street, Suite 1600 1301 Avenue of the Americas, Dallas, Texas 75201 Suite 1700 Telephone: +1 972.360.1900 New York, New York 10019 Telephone: +1 212.326.2000 DERON R. DACUS (Applications for pro hac vice (Texas Bar No. 00790553) admission pending) THE DACUS FIRM, P.C.
821 ESE Loop 323, Suite 430 Tyler, Texas 75701 Telephone: +1 903.705.1117 Counsel for Relator Novartis Pharmaceuticals Corporation
(800) 4-APPEAL • (814349) TO THE HONORABLE COURT OF APPEALS FOR THE 15TH DISTRICT:
Pursuant to the Texas Rules Governing Admission to the Bar, Rule XIX, Ross B. Galin requests permission to participate in the proceedings of the above-captioned cause. In support of this Motion, he represents that:
1. I am an attorney and partner with the law firm O’Melveny & Myers LLP. My office address is 1301 Avenue of the Americas, Suite 1700, New York, NY 10019. My telephone number is 212-326-2000, and my facsimile number is 212-326-2061.
2. I seek to be associated with Danny S. Ashby, a member of the Texas Bar.
Mr. Ashby’s Texas S tate Bar Number is 01370960. Mr. Ashby is an attorney and partner with the law firm O’Melveny & Myers LLP. His address is 2801 North Harwood S treet, S uite 1600, Dallas, TX 75201. His telephone number is 972-360- 1900, and his facsimile number is 972-360-1901.
3. My New York Bar No. is 4069035, and I am admitted in the following jurisdictions:
a. New York State Courts – 2002;
b. U.S. District Court for the Eastern District of New York – 2014;
c. U.S. District Court for the Southern District of New York – 2002;
I am an active member in good standing in the above jurisdictions.
4. I have not appeared in a Texas court within the last two (2) years, other than in the original proceeding before the 71st Judicial District of Harrison County, Texas, Cause No. 23-0276.
5. I have not been the subject of a disciplinary action by any Bar or courts of any jurisdiction in which I am licensed.
6. I have not been denied admission to the courts of any State or federal court.
7. I am familiar with the Texas State Bar, the Texas State Bar Rules, and the Texas Disciplinary Rules of Professional Conduct governing the conduct of members of the State Bar of Texas, and I will at all times abide by and comply with the same so long as such proceeding is pending and I have not withdrawn as counsel therein.
8. I have filed an Application for Pro Hac Vice Admission with and paid the required fee to the Texas Board of Law Examiners. (See Acknowledgement Letter issued by the Texas Board of Law Examiners, attached hereto as Exhibit A).
9. I request permission to participate as co-counsel of record pro hac vice, affiliated with attorney Danny S. Ashby, on behalf of Petitioner, Novartis Pharmaceuticals Corporation in Cause Number 15-25-00207-CV; In Re Novartis Pharmaceuticals Corporation, in the Fifteenth Court of Appeals of Texas.
WHEREFORE, for the above reasons, Ross B. Galin requests that this Court grant him permission to participate in the proceedings of this matter on behalf of Petitioner, Novartis Pharmaceuticals Corporation.
Signed this 26th day of November, 2025.
/s/Ross B. Galin Ross B. Galin (NY Bar No. 4069035) O’MELVENY & MYERS LLP 1301 Avenue of the Americas, Suite 1700 New York, NY 10019 Telephone: 212-326-2000 Facsimile: 212-326-2061 [email protected]
VERIFICATION
My name Ross B. Galin, my date of birth is , and my address is 1301 Avenue of the Ameri cas, Sui te 1700, New York, NY 10019. I declare under penalty of perjury that the foregoing is true and correct. Executed in New York on the 26th day of November, 2025.
/s/ Ross B. Galin Ross B. Galin
CERTIFICATE OF CONFERENCE
I certify that on November 14, 2025, Petitioner’s couns el conferred with Respondent’s counsel, Radu A. Lelutiu, regarding the relief requested in the foregoing Motion. Mr. Lelutiu indicated that he is not opposed to the requested relief. /s/Ross B. Galin Ross B. Galin
CERTIFICATE OF SERVICE
I hereby certify that on November 26, 2025, a true and correct copy of the foregoing has been filed and served on counsel of record through electronic service via www.efiletexas.gov.
/s/ Ross B. Galin Ross B. Galin
Exhibit A Board of Law Examiners Appointed by the Supreme Court of Texas November 21, 2025
Jonathan Pierre 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: Ross B. Galin Case: 15-25-00207-CV Texas court or body: Court of Appeals for the Fifteenth District of Texas
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.
Court Services on behalf of Danny Ashby Bar No. 1370960 [email protected] Envelope ID: 108502297 Filing Code Description: Motion Filing Description: Motion of Attorney Anton Metlitsky to Appear Pro Hac Vice Status as of 11/26/2025 2:56 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Deron Dacus 790553 [email protected] 11/26/2025 12:33:06 PM SENT Jonathan Wilkerson 24050162 [email protected] 11/26/2025 12:33:06 PM SENT Samuel Baxter 1938000 [email protected] 11/26/2025 12:33:06 PM SENT Zeke DeRose 24057421 [email protected] 11/26/2025 12:33:06 PM SENT Jennifer Truelove 24012906 [email protected] 11/26/2025 12:33:06 PM SENT Alex Brown 24026964 [email protected] 11/26/2025 12:33:06 PM SENT Lynne Kurtz-Citrin 24081425 [email protected] 11/26/2025 12:33:06 PM SENT Kwaku A.Akowuah [email protected] 11/26/2025 12:33:06 PM SENT Eric B.Halper [email protected] 11/26/2025 12:33:06 PM SENT Crystal Clark [email protected] 11/26/2025 12:33:06 PM SENT Chelsea A.Priest [email protected] 11/26/2025 12:33:06 PM SENT Ross Galin [email protected] 11/26/2025 12:33:06 PM SENT Meredith Garagiola [email protected] 11/26/2025 12:33:06 PM SENT Anton Metlitsky [email protected] 11/26/2025 12:33:06 PM SENT Danny S.Ashby [email protected] 11/26/2025 12:33:06 PM SENT Radu A. Lelutiu [email protected] 11/26/2025 12:33:06 PM SENT W. Mark Lanier [email protected] 11/26/2025 12:33:06 PM SENT Jordan Underhill [email protected] 11/26/2025 12:33:06 PM ERROR Jonathan D. Bonilla [email protected] 11/26/2025 12:33:06 PM ERROR Litigation Calendar [email protected] 11/26/2025 12:33:06 PM SENT Craig McAllister [email protected] 11/26/2025 12:33:06 PM SENT
Case-law data current through December 31, 2025. Source: CourtListener bulk data.