Terry Neff and Iron Workers Mid- South Pension Fund v. Nicholas F. Brady, David J. Butters, Willilam E. MacAulay, Robert B. Millard, Robert K. Moses, Jr., Robert a Rayne, Bernard J. Duroc-Danner and Burt M. Martin

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ACCEPTED 01-15-00544-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 12/2/2015 9:59:44 AM CHRISTOPHER PRINE CLERK FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS No. 01*15-00544-CV 12/2/2015 9:59:44 AM CHRISTOPHER A. PRINE IN THE FIRST COURT OF APPEALS Clerk HOUSTON, TEXAS TERRY NEFF AND IRON WORKERS MID-SOUTH PENSION FUND, Derivatively on Behalf of Weatherford Intcrnalional Ltd., Appellants, vs. NICHOLAS F. BRADY, DAVID J. BUTTERS, WILLIAM E. MACAULAY, ROBERT' B. MILLARD, ROBERT K. MOSES, JR., ROBERT A RAYNE, BERNARD J. DUROC-DANNER AND BURT M. MARTIN, AND WEATHERFORD INTERNATIONAL LTD. A SWISS CORPORATION, Appellees. Appeal from the 270th Judicial District Court Harris County, Texas No. 2010-40764 BENNY C. GOODMAN HI'S UNOPPOSED MOTION FOR PRO MAC VICE ADMISSION Joe Kendall Benny C. Goodman III SBN 11260700 CA SBN 211302 Jamie J. McKey ROBBINS GELLER RUDMAN SBN 24045262 & DO WD LLP KENDALL LAW GROUP, LLP 655 West Broadway, Suite 1900 3232 McKinney Avenue, Suite 700 San Diego, CA92101 Dallas, TX 75204 T: (619) 231-1058 j kern lall@kcnda 11lawgro up.com F:(619) 231-7423 jmckcy@kendalllawgroiip.c:om T: (214) 744-3000/F: (214) 744-3015 Attorneys for Appellants 1093752J I, Benny C. Goodman III, under the authority of the Rules Governing Admission to the Bar of Texas, Rule XIX, file this Unopposed Motion for Pro Mac Vice Admission to appear before the Court. I. FACTS 1. As a mandatory initial requirement, I have complied with the requirements of Texas Government Code §82.0361 concerning payment of a non- resident attorney fee to the Board of Law Examiners. A true and correct copy of the Non-Resident Acknowledgment Letter is attached hereto as Exhibit A. I am associated with Jamie J. McKey of Kendall Law Group, who will personally participate in the proceedings of this case. Jamie J. McKey is a practicing attorney and a member of the State Bar of Texas. Ms. McKey's State Bar card number is 24045262 and her office address, telephone number, and facsimile number are: Kendall Law Group, LLP, 3232 McKinney Avenue, Suite 700, Dallas, Texas 75204, Telephone: (214) 744-3000, Facsimile: (214) 744-3015. 3. I am an active member in good standing of the following jurisdictions: State of California; U.S. District Court for Northern, Central, and Southern Districts of California; United States District Court for the District of Columbia; and the U.S. Court of Appeals for the D.C., Sixth and Seventh Circuits. 4. I have not been the subject of disciplinary action in the last five years by the bar or courts of any jurisdiction in which I am licensed, 1093752J 5. 1 have not been denied admission to the courts of any state or to any federal court during the last five years. 6. 1 am familiar with the State Bar Act, the State Bar Rules, and the Texas Disciplinary Rules of Professional Conduct governing conduct of members of the State Bar of Texas, and T will abide by and comply with those rules as long as this cause of action is pending. 1 have not appeared or sought leave to appear in the following Texas State courts in the last two years. 8. My office address, telephone number, and facsimile number are: Robbins Geller Rudman & Dowd LLP, 655 West Broadway, Suite 1900, San Diego, CA 92101, Telephone: (619) 2,314058, Fax: (619) 231-7423. II. PRAYER For these reasons, I ask this Court to grant my Unopposed Motion for Pro Mac Vice Admission and to allow me to appear before this Court until the conclusion of this cause of action. DATED: November 30, 2015 Respectfully submitted, ROBBINS GELLER RUDMAN & DOWD LLP BENNY C. GOODMAN 111 tv/&- _ IP1 BENNY C. GOODMAN III 1093752J 655 West Broadway, Suite 1900 San Diego, CA 92101 T: (619) 231-1058 F: (619) 231-7423 KENDALL LAW GROUP, LLP JOE KENDALL JAMIE J. MCKEY 3232 McKinney Avenue, Suite 700 Dallas, TX 75204 T: (214) 744-3000 F: (214) 744-3015 Attorneys for Appellants -3- 1093752_1 CERTIFICATE OF CONFERENCE As required by Texas Rule of Appellate Procedure 10.1(a)(5), I hereby certify that counsel for Appellants conferred with counsel for Appellees regarding Benny C. Goodman III Motion for Pro Hac Vice Admission. Counsel for Appellees confirmed that Appellees do not oppose the motion. 'feW /H BENNY C. GOODMAN III - 4- 1093752J AFFIDAVIT STATE OF CALIFORNIA ) ) ss: COUNTY OF SAN DIEGO ) Comes now Benny C. Goodman III, of lawful age, being first duly sworn, and states for his affidavit supporting the within Unopposed Motion for Pro Hac Vice Admission that the above-mentioned facts are true based upon his knowledge, information, and belief. .&* M BENNY C. GOODMAN III Sworn to and subscribed before me this 30th day of November, 2015 Notary Public, Stated)I' California My commission expires: /&M/ A Notary Public or other officer / j 'ilfrrV I Z 1w m m DEBORAH O.'HAYES' Commission # 2126468 t Notary Public • California San Diego County My Comm. Expires Oct 9.2019[ g completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document. 1093752J EXHIBIT A Board of Law Examiners Appointed by the Supreme Court otT cxas P.O.Box 13480 * Austin,! exas 73711-3466 Arknowled^mcnt Letter Non-Resident Attorney Fee November 20, 2015 To: spatel@rgrdlaw.com Via: spateI@rgrdla\v.com According to Texas Governmont Code §02.0361, "a nonresident attorney requesting permission to participate in proceedings in a court in this state shall pay a foe of $250 for each case in which the attorney is requestingt o participate." This Acknowledgement Letter serves as prooft halt he Board of Law Examiners has received $250 in connection with the following matter: Non-resident attorney; Benny C. Goodman III Case: 01-15 •00544-CV I exas court or body: First Court of Appeals Houston Texas After satisfying the fee requirement, a non-resident attorney shall file a motion in the Texas court or body in vWiich the non-resident attorney is requesting permission to appear. The motion shall contain the information and statements required by Rule XIX(a) of the Rules Governing Admission to the Bar of Texas. The motion must be accompanied by tfiTs Acknowledgment L etter and by a motion from a resident practicing Texas attorney that contains the statements required by Rule XIX(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 iti s filed. For more information, please see Rule XIX 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. Sincerely, Susan Henricks Executive Director CERTIFICATE OF SERVICE I hereby certify that on December 1, 2015, a true and correct copy of the foregoing motion was served on the following counsel in the manner indicated: James A. Reeder, Jr. Rebecca N. Brandt Jeffrey S. Johnston LATHAM & WATKINS LLP Stacy M. Neal 811 Main Street, Suite 3700 Nicholas Shum Houston, TX 77002 Stephanie Miller rebecca.brandt@lw.com VINSON & ELK1NS LLP VIA E-FILE AND E MAIL 1001 Fannin St., Suite 2500 Houston, TX 77002 jreeder@velaw.coni jjohnston@velaw.com sneal@velaw.coni nshum@velaw.com smiller@velaw.com VIA E-FILE AND E-MAIL N. Scott Fletcher Peter A. Wald Elizabeth G. Myers LATHAM & WATKINS LLP JONES DAY 505 Montgomery Street, Suite 2000 717 Texas, Suite 3300 San Francisco, CA 94111 Houston, TX 77002 peter.wald@lw.com sfletcher@jonesday.com VIA E-FILE AND E-MAIL egmyers@jonesday.com VIA E-FILE AND E-MAIL Robert S. Bennett Kevin H. Metz Ellen Kennedy LATHAM & WATKINS LLP HOGAN LOVELLS US LLP 555 Eleventh Street NW, Suite 1000 555 Thirteenth Street, NW Washington, DC 20004 Washington, DC 20004 kevin.metz@lw.com robcrt.bennctt@hoganlovells.com VIA E FILE AND E MAIL ellen.kennedy@hoganlovells.com VIA E FILE AND E-MAIL 1093752_1 Noelle M. Reed Charles W. Schwartz SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP 1000 Louisiana Street, Suite 6800 Houston, TX 77002 noelle.reed@skadden.coin charles.schwartz@skadden.com VTA E-FILE AND E-MAIL / JL Y C. GOODMAN 111 1093752 _1