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

Court of Appeals of Texas·Decided March 18, 2025·No. 15-25-00021-CV·Published

Opinion

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) 600 Congress, Suite 2900 Stefan P. Schropp Austin, Texas 78701 (Pro hac pending) eburbach@foley.com 2099 Pennsylvania Ave., N.W. sobenhaus@foley.com Washington, D.C. 20006-6807 Tel: 512.542.7070 samantha.badlam@ropesgray.com George Valton (“Val”) Jones stefan.schropp@ropesgray.com (No. 10888050) Tel: 202.508.4734 109 West Austin St. Marshall, Texas 75670-3340 Counsel for Pfizer Inc. val@valjoneslaw.com 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 Stefan.schropp@ropesgray.com (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 600 Congress Avenue, Suite 2900 Austin, Texas 78701 eburbach@foley.com 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 stefan.schropp@ropesgray.com (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 jtb@jtblawgroup.com Jordan Underhill Patrick S. Almonrode Vivian Egbu patalmonrode@jtblawgroup.com 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. jonathan.bonilla@oag.texas.gov Michael E. Jones jordan.underhill@oag.texas.gov mikejhones@potterminton.com vivian.egbu@oag.texas.gov E. Glenn Thames, Jr. brittany.Peters@oag.texas.gov glennthames@potterminton.com (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 memberservices@dcbar.org.

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

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Pfizer Inc. and Tris Pharma, Inc. v. the State of Texas and Tarik Ahmed, (Tex. Ct. App. 2025).

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Related

§ 82.0361
Texas GV § 82.0361