*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 12/2/2015 9:59:44 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00544-CV

FIRST COURT OF APPEALS HOUSTON, TEXAS 12/2/2015 9:59:44 AM CHRISTOPHER PRINE CLERK No. 01*15-00544-CV IN THE FIRST COURT OF APPEALS 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 Benny C. Goodman III Joe Kendall CA SBN 211302

SBN 11260700 ROBBINS GELLER RUDMAN

Jamie J. McKey & DO WD LLP

SBN 24045262 655 West Broadway, Suite 1900

KENDALL LAW GROUP, LLP San Diego, CA92101

3232 McKinney Avenue, Suite 700 T: (619) 231-1058

Dallas, TX 75204 F:(619) 231-7423

j kern lall@kcnda 11 lawgro up .com

jmckcy@kendalllawgroiip.c:om

T: (214) 744-3000/F: (214) 744-3015

Attorneys for Appellants

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,

5. 1 have not been denied admission to the courts of any state or to any federal

court during the last five years. 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. Respectfully submitted,

DATED: November 30, 2015

ROBBINS GELLER RUDMAN & DOWD LLP BENNY C. GOODMAN 111 IP1 tv/&- _ BENNY C. GOODMAN III *4 655 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. /H

'feW BENNY C. GOODMAN III - 4 -

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.

.&* BENNY C. GOODMAN III Sworn to and subscribed before me this 30th day of November, 2015

t Notary Public, Stated)I' California j 'ilfrrV DEBORAH O.'HAYES' I Commission # 2126468 /&M/ / Notary Public • California My commission expires: San Diego County g Z 1 My Comm. Expires Oct 9.2019 [ w m m A Notary Public or other officer

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.

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 Peter A. Wald

N. Scott Fletcher

Elizabeth G. Myers LATHAM & WATKINS LLP 505 Montgomery Street, Suite 2000

JONES DAY San Francisco, CA 94111

717 Texas, Suite 3300 peter.wald@lw.com

Houston, TX 77002 VIA E-FILE AND E-MAIL

sfletcher@jonesday.com

egmyers@jonesday.com

VIA E-FILE AND E-MAIL Kevin H. Metz

Robert S. Bennett

Ellen Kennedy LATHAM & WATKINS LLP

HOGAN LOVELLS US LLP 555 Eleventh Street NW, Suite 1000 Washington, DC 20004

555 Thirteenth Street, NW

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