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

Court of Appeals of Texas·Decided April 11, 2025·No. 15-25-00021-CV·Published

Opinion

ACCEPTED 15-25-00021-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 4/11/2025 3:48 PM No. 15-25-00021-CV CHRISTOPHER A. PRINE CLERK In the Fifteenth Court of Appeals FILED IN 15th COURT OF APPEALS Austin, Texas AUSTIN, TEXAS

4/11/2025 3:48:53 PM

PFIZER INC. and TRIS PHARMA, INC., CHRISTOPHER Clerk A. PRINE

Petitioners/Defendants, v.

The STATE OF TEXAS and TARIK AHMED, Respondents/Plaintiffs.

Permissive Appeal from the 71st Judicial District Court, Harrison County, Texas

WILLIAM E. LAWLER’S UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION

William E. Lawler III BLANK ROME LLP 1825 Eye St. N.W. Washington, D.C. 20006-5403 william.lawler@blankrome.com Tel: 202.420.2249 Fax: 202.330.5460 ATTORNEY FOR PETITIONER/DEFENDANT, TRIS PHARMA, INC.

TO THE HONORABLE COURT OF APPEALS:

I, William E. Lawler, 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 Petitioner/Defendant,TRIS

PHARMA, INC., and would show the Court the following:

I. FACTS

1. My contact information is as follows:

BLANK ROME LLP 1825 Eye St. N.W. Washington, D.C. 20006-5403 Tel: 202.420.2249 Fax: 202.330.5460 william.lawler@blankrome.com

2. I am associated with resident attorney Harry “Gil” Gillam, Jr. who

will personally participate in the appeal of this case on behalf of

Petitioner/Defendant, TRIS PHARMA, INC. He is a practicing attorney and a

member in good standing with the State Bar of Texas. His state bar number and

contact information is as follows:

Harry “Gil” Gillam, Jr. State No. 07921800 GILLAM & SMITH LLP 303 S. Washington Ave. Tel: 903- 934-8450 Fax: 903-934-9257 gil@gillamsmithlaw.com

Mr. Harry “Gil” Gillam, Jr is concurrently filing an unopposed motion

recommending that I be granted permission to participate in the proceeding

before the Court. Exhibit A.

3. I am an active member in good standing in District of Columbia

[398951] adm 05/12/1986; Maryland [8512010354]; USDC-ED New York;

USDC-SD Texas; USDC Virgins Islands; US COA Dist of Columbia; US COA

Fifth Circuit; US COA Second Circuit. I have not been the subject of disciplinary

action by the Bar or courts of any jurisdiction in which I have been licensed. A

certificate of good standing from the District of Columbia is attached hereto as

Exhibit A.

4. I have not been denied admission to the courts of any state or to any

federal court during the last five (5) years.

5. 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.

6. In the last two (2) years, I have Not appeared in cases in Texas courts.

7. Proof of payment from the Board of Law Examiners is attached as

Exhibit B.

II. 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.

Respectfully submitted,

/s/ William E. Lawler III William E. Lawler III BLANK ROME LLP 1825 Eye St. N.W. Washington, D.C. 20006-5403 william.lawler@blankrome.com Tel: 202.420.2249 Fax: 202.330.5460 ATTORNEY FOR PETITIONER/DEFENDANT, TRIS PHARMA, INC.

DECLARATION

My name is William E. Lawler III, my date of birth is May 21, 1960, and my business address is 1825 Eye St. N.W, Washington, D.C. 20006-5403, United States of America. I declare under penalty of perjury that the foregoing is true and correct.

Executed in District of Columbia on the 11th day of April 2025.

/s/ William E. Lawler III William E. Lawler III

CERTIFICATE OF SERVICE I hereby certify that 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 Appellate Procedure on April 11, 2025. COUNSEL FOR PETITIONER/DEFENDANT PFIZER, INC.:

FOLEY & LARDNER LLP Edward D. (“Ed”) Burbach Texas State Bar No. 03355250 Stacy R. Obenhaus Texas State Bar No. 15161570 600 Congress Avenue, Suite 2900 Austin, Texas 78701 eburbach@foley.com sobenhaus@foley.com (512) 542-7070

THE VAL JONES LAW FIRM George Valton (“Val”) Jones Texas State Bar No. 10888050 109 West Austin St. Marshall, TX 75670-3340 val@valjoneslaw.com (903) 927-2220

ROPES & GRAY LLP Samantha Barrett Badlam (application for pro hoc admission pending) Stefan P. Schropp (application for pro hoc admission pending) 2099 Pennsylvania Ave., N.W. Washington, DC 20006-6807 samantha.badlam@ropesgray.com stefan.schropp@ropesgray.com (202) 508-4734

COUNSEL FOR RESPONDENT/PLAINTIFF THE STATE OF TEXAS:

Jonathan Bonilla Texas State Bar No. 24073939 Jordan Underhill Texas State Bar No. 24102586 Vivian Egbu Texas State Bar No. 24079078 Brittany Peters Texas State Bar No. 24124762 Office of the Attorney General, Civil Medicaid Fraud Division P.O. Box 12548, Capitol Station Austin, TX 78711-2548 jonathan.bonilla@oag.texas.gov jordan.underhill@oag.texas.gov vivian.egbu@oag.texas.gov brittany.Peters@oag.texas.gov (512) 475-4169

COUNSEL FOR RESPONDENT/PLAINTIFF TARIK AHMED:

BROWN, LLC Jason T. Brown jtb@jtblawgroup.com Patrick S. Almonrode patalmonrode@jtblawgroup.com 111 Town Square Place, Suite 400 Jersey City, NJ 07310 (877) 561-0000

POTTER MINTON, P.C. Michael E. Jones mikejhones@potterminton.com E. Glenn Thames, Jr. glennthames@potterminton.com 102 North College, Suite 900 Tyler, TX 75702 (903) 597-8311

/s/ Harry “Gil” Gillam, Jr.

Harry “Gil” Gillam, Jr.

No. 15-25-00021-CV

In the Fifteenth Court of Appeals Austin, Texas

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

MOTION OF HARRY GILLAM, JR. IN SUPPORT OF MOTION TO ADMIT WILLIAMS E. LAWLER PRO HAC VICE

TO THE HONORABLE COURT OF APPEALS:

I, Harry “Gil” Gillam, Jr., hereby declare under penalty of perjury

under the laws of the United States of America:.

a. My office address is 303 South Washington Avenue, Marshall, Texas

75670. My office telephone number is (903) 934-8450. My office

facsimile number is (903) 934-9257. My email address is

gil@gillamsmithlaw.com.

b. I am familiar with William E. Lawler, and I find him to be a reputable

attorney and recommend that he be granted permission to participate in

the particular proceeding before the court.

I declare under penalty of perjury of the laws of the United States of America

that the foregoing is true and correct

Dated: April ,2025 Respectfully submitted,

By:/s/ Harry “Gil” Gillam, Jr.

Harry “Gil” Gillam, Jr. Texas State Bar. No. 07921800 gil@gillamsmithlaw.com 303 S. Washington Ave. Marshall, Texas 75670 (903) 934-8450 (telephone) (903) 934-9257 (facsimile)

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

William E Lawler III was duly qualified and admitted on May 12, 1986 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 18, 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

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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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§ 82.0361
Texas GV § 82.0361