Texas Court of Appeals, 15th District, 2025

Glenn Hegar, Comptroller of Public Accounts of the State of Texas and Ken Paxton, Attorney General of the State of Texas v. Championx, LLC

Glenn Hegar, Comptroller of Public Accounts of the State of Texas and Ken Paxton, Attorney General of the State of Texas v. Championx, LLC
Texas Court of Appeals, 15th District · Decided February 12, 2025
Glenn Hegar, Comptroller of Public Accounts of the State of Texas and Ken Paxton, Attorney General of the State of Texas v. Championx, LLC

Opinion

ACCEPTED 15-24-00111-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 2/12/2025 10:54 AM No. 15-24-00111-CV CHRISTOPHER A. PRINE CLERK FILED IN IN THE COURT OF APPEALS 15th COURT OF APPEALS AUSTIN, TEXAS FOR THE FIFTEENTH JUDICIAL DISTRICT 2/12/2025 10:54:01 AM AUSTIN, TEXAS CHRISTOPHER A. PRINE Clerk

Glenn Hegar, Comptroller of Public Accounts of the State of Texas, and Ken Paxton, Attorney General of the State of Texas Appellants, v. ChampionX, LLC, Appellee.

On Appeal from the 419th Judicial District Court Travis County, Texas Cause No. D-1-GN-20-000139

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF

Deborah S. Sloan John M. Allan State Bar No. 00786230 [email protected] [email protected] Antoinette L. Ellison Jones Day [email protected] 2727 N. Harwood Street Jones Day Suite 500 1221 Peachtree Street NE Dallas, Texas 75201-1515 Suite 400 Atlanta, Georgia 30361 Counsel for Appellee

TO THE HONORABLE JUSTICES OF THE FIFTEENTH COURT OF APPEALS: Appellee ChampionX, LLC files this Unopposed Motion for Extension of Time to File Appellee’s Brief, pursuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), and states as follows: Appellee’s Brief is currently due on February 26, 2025. By this Motion for Extension of Time, Appellee requests a 30-day extension to file its brief, making the new deadline to file March 28, 2025.

This extension is necessary because counsel for Appellee has existing out-of- state travel arrangements from February 14, 2025 through February 17, 2025 and February 26, 2025 through March 2, 2025, in addition to obligations that impact counsel’s ability to prepare and file Appellee’s Brief by the current deadline. These include preparation for and participation in a hearing before the Texas State Office of Administrative Hearings (“SOAH”), SOAH Docket Nos. 304-25-05500 and 304- 25-05501, scheduled for February 27, 2025. Counsel also has significant discovery and other responsibilities relating to an administrative appeal before the Massachusetts Appellate Tax Board as well as attending to other client obligations.

This extension is not sought for the purpose of delay, but to enable counsel to prepare and submit a brief that assists the Court. This is Appellee’s first request for an extension of time to file its Brief.

As set forth in the Certificate of Conference, this Motion for Extension of Time is unopposed.

Conclusion & Prayer For the reason described above, Appellee respectfully requests that the Court grant this Motion for a 30-day extension of time, extending the deadline to file Appellee’s Brief until March 28, 2025.

Dated: February 12, 2025

Respectfully submitted, /s/Deborah S. Sloan Deborah S. Sloan State Bar No. 00786230 [email protected] Jones Day 2727 N. Harwood Street, Suite 500 Dallas, Texas 75201-1515 John M. Allan [email protected] Antoinette L. Ellison [email protected] Jones Day 1221 Peachtree Street NE, Suite 400 Atlanta, Georgia 30361 Counsel for Appellee

CERTIFICATE OF CONFERENCE Pursuant to Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I have conferred with Kelsey Hanson, counsel for the Appellants, and she has indicated that Appellants are unopposed to the relief sought by this motion for extension of time.

/s/Antoinette L. Ellison Antoinette L. Ellison

CERTIFICATE OF SERVICE

By my signature below, I certify that on February 12, 2025 a true and correct copy of the foregoing Unopposed Motion for Extension of Time to File Appellee’s Brief was served on the following counsel of record via e-service: Kelsey Hanson Assistant Attorney General State Bar No. 24096654 Tax Litigation Division P.O. Box 12548 Austin, Texas 78711-2548 512-463-8897 512-478-4013 (fax) [email protected]

Attorneys for Appellants

/s/ Deborah S. Sloan Deborah S. Sloan

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.

Carla Dennis on behalf of Deborah Sloan Bar No. 786230 [email protected] Envelope ID: 97283157 Filing Code Description: Motion Filing Description: ChampionX Unopposed Motion for Extension of Time to File Appellees Brief Status as of 2/12/2025 11:02 AM CST Associated Case Party: ChampionX, LLC Name BarNumber Email TimestampSubmitted Status Deborah Sloan 786230 [email protected] 2/12/2025 10:54:01 AM SENT Carla Dennis [email protected] 2/12/2025 10:54:01 AM SENT John MAllan [email protected] 2/12/2025 10:54:01 AM SENT Antoinette L.Ellison [email protected] 2/12/2025 10:54:01 AM SENT

Associated Case Party: Ken Paxton, Attorney General of the State of Texas Name BarNumber Email TimestampSubmitted Status Kelsey Hanson 24096654 [email protected] 2/12/2025 10:54:01 AM SENT

Case-law data current through December 31, 2025. Source: CourtListener bulk data.