Kelly Hancock, Acting Texas Comptroller of Public Accounts v. the Neiman Marcus Group

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
socarroll@reevesbrightwell.com
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)
jturner@baileycav.com
Brittany P. Stephen
(pro hac vice application forthcoming)
bstephen@baileycav.com
John P. Miller
(pro hac vice application forthcoming)
jmiller@baileycav.com
10 West Broad Street, Suite 2100
Columbus, Ohio 43215
Telephone (614) 221-3155
Facsimile (614) 221-0479

Attorneys for The Neiman Marcus Group
LLC

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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.

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Respectfully submitted,

/s/ Sinéad O’Carroll
Sinéad O’Carroll
State Bar No. 24013253
socarroll@reevesbrightwell.com
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

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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
terri.abernathy@oag.texas.gov

Counsel for Appellant Kelly Hancock,
Acting Texas Comptroller of Public Accounts

/s/ Sinéad O’Carroll
Sinéad O’Carroll

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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
socarroll@reevesbrightwell.com
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)
jturner@baileycav.com
Brittany P. Stephen
(pro hac vice application forthcoming)
bstephen@baileycav.com
John P. Miller
(pro hac vice application forthcoming)
jmiller@baileycav.com
10 West Broad Street, Suite 2100
Columbus, Ohio 43215
Telephone (614) 221-3155
Facsimile (614) 221-0479

Attorneys for The Neiman Marcus Group
LLC

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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
10 W. Broad Street, Suite 2100
Columbus, Ohio 43215
T: 614-221-3155
F: 614-221-0479
jmiller@baileycav.com

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
socarroll@reevesbrightwell.com

Ms. O’Carroll is concurrently filing an unopposed motion recommending

that I be granted permission to participate in the proceeding before the Court.

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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.

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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)
10 West Broad Street, Suite 2100
Columbus, Ohio 43215
T: (614) 221-3155
F: (614) 221-0479
jturner@baileycav.com
bstephen@baileycav.com
jmiller@baileycav.com

Attorneys for The Neiman Marcus Group
LLC

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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

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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
sfarris@reevesbrightwell.com
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 terri.abernathy@oag.texas.gov 12/19/2025 12:04:23 PM SENT

Victoria Gomez victoria.gomez@oag.texas.gov 12/19/2025 12:04:23 PM SENT

Sinead O'Carroll socarroll@reevesbrightwell.com 12/19/2025 12:04:23 PM SENT

Jameel S.Turner jturner@baileycav.com 12/19/2025 12:04:23 PM SENT

Brittany P.Stephen bstephen@baileycav.com 12/19/2025 12:04:23 PM SENT

John P. Miller jmiller@baileycav.com 12/19/2025 12:04:23 PM SENT

Susan Farris sfarris@reevesbrightwell.com 12/19/2025 12:04:23 PM SENT