ACCEPTED 15-25-00145-cv FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 12/19/2025 12:04 PM No. 15-25-00145-CV CHRISTOPHER A. PRINE CLERK IN THE COURT OF APPEALS FILED IN 15th COURT OF APPEALS FOR THE FIFTEENTH JUDICIAL DISTRICTAUSTIN, TEXAS AUSTIN, TEXAS 12/19/2025 12:04:23 PM CHRISTOPHER A. PRINE Clerk

Kelly Hancock, Acting Texas Comptroller of Public Accounts Appellant v. The Neiman Marcus Group, LLC Appellee

Interlocutory Appeal from 200th Judicial District Court of Travis County, Texas UNOPPOSED MOTION IN SUPPORT OF ADMISSION PRO HAC VICE OF JOHN P. MILLER REEVES & BRIGHTWELL LLP Sinéad O’Carroll State Bar No. 24013253 [email protected] 3103 Bee Caves Rd, Suite 240 Austin, TX 78746 Telephone (512) 334-4500 Facsimile (512) 334-4492

-1- BAILEY CAVALIERI LLC Jameel S. Turner (pro hac vice application forthcoming) [email protected] Brittany P. Stephen (pro hac vice application forthcoming) [email protected] John P. Miller (pro hac vice application forthcoming) [email protected] West Broad Street, Suite 2100 Columbus, Ohio 43215 Telephone (614) 221-3155 Facsimile (614) 221-0479 Attorneys for The Neiman Marcus Group LLC

-2- I, Sinéad O’Carroll, file this Unopposed Motion in Support of John P. Miller’s Motion for Pro Hac Vice Admission to appear before this Court, which is attached hereto as Exhibit A, and would respectfully show the Court the following: 1. I am associated with John P. Miller in this case. I am employed as an attorney on this case and will personally participate in the litigation of this case on behalf of Appellee The Neiman Marcus Group LLC.

2. I am a practicing attorney and a member in good standing with the State Bar of Texas. My state bar number, office address, telephone number, fax number, and email address are included in my signature below.

3. I find John P. Miller to be a reputable attorney, and I recommend that the Court grant him permission to participate in this proceeding before the Court.

PRAYER For these reasons, I ask the Court to grant John P. Miller’s Unopposed Motion for Pro Hac Vice Admission and allow him to appear before this Court in this proceeding until the conclusion of this case.

-3- Respectfully submitted, /s/ Sinéad O’Carroll Sinéad O’Carroll State Bar No. 24013253 [email protected] 3103 Bee Caves Rd, Suite 240 Austin, Texas 78746 Telephone (512) 334-4500 Facsimile (512) 334-4492 Counsel for The Neiman Marcus Group LLC

CERTIFICATE OF CONFERENCE I hereby certify that on December 2, 2025, counsel for Appellee conferred with Terri Abernathy, counsel for Appellant Kelly Hancock, Acting Texas Comptroller of Public Accounts, who stated that Appellant’s does not oppose the relief sought herein.

/s/ Sinéad O’Carroll Sinéad O’Carroll

-4- CERTIFICATE OF SERVICE I hereby certify that on December 19, 2025, a true and correct copy of the foregoing instrument was forwarded to all counsel of record by electronic filing in accordance with the Texas Rules of Civil Procedure.

Terri M. Abernathy Assistant Attorney General OFFICE OF THE ATTORNEY GENERAL OF TEXAS General Litigation Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 [email protected] Counsel for Appellant Kelly Hancock, Acting Texas Comptroller of Public Accounts

/s/ Sinéad O’Carroll Sinéad O’Carroll

-5- EXHIBIT A No. 15-25-00145-CV IN THE COURT OF APPEALS FOR THE FIFTEENTH JUDICIAL DISTRICT AUSTIN, TEXAS

Kelly Hancock, Acting Texas Comptroller of Public Accounts Appellant v. The Neiman Marcus Group, LLC Appellee

Interlocutory Appeal from 200th Judicial District Court of Travis County, Texas

MOTION FOR ADMISSION PRO HAC VICE OF JOHN P. MILLER

REEVES & BRIGHTWELL LLP Sinéad O’Carroll State Bar No. 24013253 [email protected] 3103 Bee Caves Rd, Suite 240 Austin, TX 78746 Telephone (512) 334-4500 Facsimile (512) 334-4492

-1- BAILEY CAVALIERI LLC Jameel S. Turner (pro hac vice application forthcoming) [email protected] Brittany P. Stephen (pro hac vice application forthcoming) [email protected] John P. Miller (pro hac vice application forthcoming) [email protected] West Broad Street, Suite 2100 Columbus, Ohio 43215 Telephone (614) 221-3155 Facsimile (614) 221-0479 Attorneys for The Neiman Marcus Group LLC

-2- I, John P. Miller, move the 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 Appellee The Neiman Marcus Group, and would show the Court the following: 1. My contact information is as follows: Bailey Cavalieri LLC W. Broad Street, Suite 2100 Columbus, Ohio 43215 T: 614-221-3155 F: 614-221-0479 [email protected] 2. I am associated with resident attorney Sinead O’Carroll who will personally participate in this case on behalf of Appellee The Neiman Marcus Group. Ms. O’Carroll is a practicing attorney and a member in good standing with the State Bar of Texas. Her state bar number and contact information is as follows: Sinéad O’Carroll State Bar No. 24013253 Reeves & Brightwell LLP 3103 Bee Caves Rd, Suite 240 Austin, Texas 78746 T: 512-334-4500 F: 512-334-4492 [email protected] Ms. O’Carroll is concurrently filing an unopposed motion recommending that I be granted permission to participate in the proceeding before the Court.

-3- 3. I am an active member in good standing in the State of Ohio. 4. I have not been the subject of disciplinary action by the Bar or courts of any jurisdiction in which I have been licensed.

5. I have not been denied admission to the courts of any state or to any federal court during the last five (5) years.

6. 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 State Bar of Texas. I will at all times abide by and comply with those rules as long as this cause of action is pending and I have not withdrawn as counsel from the proceeding.

7. In the last two (2) years, I have appeared in 1 case in Texas courts: i. The Neiman Marcus Group LLC v. Glenn Hager, Texas Comptroller of Public Accounts, Cause No. D-1-DN-24- 005004, District Court of Travis County, Texas, Appealed.

8. Proof of payment from the Board of Law Examiners is attached as Exhibit 1.

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

-4- Respectfully submitted, BAILEY CAVALIERI LLC /s/ John P. Miller Jameel S. Turner OH SBN 0078251 (pro hac vice application forthcoming) Brittany P. Stephen OH SBN 0092178 (pro hac vice application forthcoming) John P. Miller OH SBN 0097161 (pro hac vice application forthcoming) West Broad Street, Suite 2100 Columbus, Ohio 43215 T: (614) 221-3155 F: (614) 221-0479 [email protected] [email protected] [email protected] Attorneys for The Neiman Marcus Group LLC

-5- DECLARATION My name is John P. Miller, my date of birth is October 1, 1989, and my business address is 10 W. Broad Street, Suite 2100, Columbus, OH 43215, United States of America. I declare under penalty of perjury that the foregoing is true and correct.

Executed in Franklin County, State of Ohio on the 18th day of December 2025.

/s/ John P. Miller John P. Miller

-6- EXHIBIT 1 Board of Law Examiners Appointed by the Supreme Court of Texas December 15, 2025

John Miller 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: John Miller Case: 15-25-00145-CV Texas court or body: The Court of Appeals for the Fifteenth Judicial District

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.

Susan Farris on behalf of Sinead O'Carroll Bar No. 24013253 [email protected] Envelope ID: 109307379 Filing Code Description: Motion Filing Description: Unopposed Motion in Support of Admission Pro Hac Vice of John P. Miller Status as of 12/19/2025 12:36 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Terri Abernathy [email protected] 12/19/2025 12:04:23 PM SENT Victoria Gomez [email protected] 12/19/2025 12:04:23 PM SENT Sinead O'Carroll [email protected] 12/19/2025 12:04:23 PM SENT Jameel S.Turner [email protected] 12/19/2025 12:04:23 PM SENT Brittany P.Stephen [email protected] 12/19/2025 12:04:23 PM SENT John P. Miller [email protected] 12/19/2025 12:04:23 PM SENT Susan Farris [email protected] 12/19/2025 12:04:23 PM SENT