Courtenay Paris, in Her Personal Capacity, and in Her Official Capacity as Chairperson on Behalf of Decriminalize Elgin, a Nonprofit, Unincorporated Political Action Committee v. the State of Texas; City of Elgin; Theresa Y. McShan, Mayor of Elgin; Sue Brashar, Mayor Pro Tem of Elgin; Joy Casnovsky, Arthur Gibson III, Yalecia Love, Chuck Swain, Matthew Callahan, Al Rodriguez, and Forest Lee Dennis, Members of the City Council of Elgin; Thomas Mattis, City Manager of Elgin; And Chris Noble, Chief of Police of Elgin; In Their Official Capacities

ACCEPTED 15-24-00082 FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 2/12/2025 3:03 PM LAW OFFICE OF RICHARD GLADDEN CHRISTOPHER A. PRINE CLERK 1204 WEST UNIVERSITY DRIVE, SUITE 307 DENTON, TEXAS 76201 FILED IN 15th COURT OF APPEALS 940-323-9300 (Voice) AUSTIN, TEXAS 940-539-0093 (Fax) 2/12/2025 3:03:52 PM CHRISTOPHER A. PRINE February 12, 2025 Clerk

Christopher A. Prine, Clerk Fifteenth Court of Appeals William P. Clements Building W. 15th Street, Suite 607 Austin, Texas 78701 Re: No. 15-24-00082, Paris v. State of Texas, in the Fifteenth Court of Appeals, Austin, Texas.

Dear Mr. Prine, I would appreciate it if you would deliver this letter to the Honorable Presiding Justice and Associate Justices of the Fifteenth Court of Appeals.

This morning, after observing the oral argument heard by the Fifteenth Court of Appeals in State of Texas v. Harris County, No. 15-24-00120-CV (oral argument heard Feb. 12, 2025), undersigned Counsel for Appellant Courtenay Paris in the instant case discovered, for the first time, that the Appellees in State of Texas v. Harris County, supra, have raised during oral argument (and have raised in their brief on appeal) the question of whether the Attorney General of Texas may initiate civil litigation in a state district court without authority that has been expressly delegated by either Article IV, § 22 of the Texas Constitution (“Article IV, § 22”), or by any statute enacted by the Texas Legislature.1 This letter is submitted primarily for the purpose of alerting the Court of Appeals to the fact that Appellant Paris, on the present appeal, has previously raised the identical issue.2 Furthermore, Appellant Paris notes the Court of Appeals’ resolution of her issue raised under Article IV, § 22 may render moot the other pending appeals also heard by the Court at oral argument on February 12, 2025, i.e., State of Texas v. City of Austin, No. 15-24-00077-CV (Tex. App. – Austin [15th Dist.]); and State of Texas v. City of San Marcos, No. 15-24-00084-CV (Tex. App. – Austin [15th Dist.]) On the present appeal all appellate briefing by the opposing parties has concluded, but the Court of Appeals has not yet determined whether Appellant Paris’ appeal will be submitted with or without oral argument. In addition to what has been stated above, Appellant Paris again requests her appeal in this case be set for submission with oral argument so that she may address not only her issue arising under Article IV, § 22, as described above, but also the other relatively complex issues she has raised on her appeal.

Brief of Appellee Harris County, et al., No. 15-24-00120-CV, pages 16-30 (Tex. App. – Austin [15th Dist.]) (filed Jan. 14, 2025).

Appellant Paris’ Brief, pages 26-39 (No. 15-24-00082, filed Oct. 21, 2024); Appellant Paris’ Reply Brief, pages 9-11 (No. 15-24-00082, filed Jan. 9, 2025).

Respectfully submitted, /s/Richard Gladden State Bar No. 07991330 1204 West University Dr., Ste. 307 Denton, Texas 76201940/323-9300 (Voice) 940/539-0093 (Fax) [email protected] (email) Attorney for Appellant Courtenay Paris cc: All counsel of record (via ECF)

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Richard Gladden Bar No. 07991330 [email protected] Envelope ID: 97303850 Filing Code Description: Letter Filing Description: Appellant's Letter Brief Concerning Related Case Status as of 2/12/2025 3:07 PM CST Associated Case Party: Courtenay Paris Name BarNumber Email TimestampSubmitted Status Richard Gladden [email protected] 2/12/2025 3:03:52 PM SENT Terri Sparks [email protected] 2/12/2025 3:03:52 PM SENT

Associated Case Party: The State of Texas Name BarNumber Email TimestampSubmitted Status Cory Scanlon 24104599 [email protected] 2/12/2025 3:03:52 PM SENT

Associated Case Party: City of Elgin, Texas Name BarNumber Email TimestampSubmitted Status Gabrielle Smith 24093172 [email protected] 2/12/2025 3:03:52 PM SENT