Glenn Hegar, Comptroller of Public Accounts of the State of Texas and Ken Paxton, Attorney General of the State of Texas v. American Airlines, Inc.

ACCEPTED 15-24-00113-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 2/20/2025 3:53 PM Cause No. 15-24-00113-CV CHRISTOPHER A. PRINE CLERK In the Court of Appeals FILED IN 15th COURT OF APPEALS for the Fifteenth District of Texas AUSTIN, TEXAS 2/20/2025 3:53:34 PM Glen Hegar, Comptroller of Public Accounts of TheA. PRINE CHRISTOPHER Clerk State of Texas and Ken Paxton, Attorney General of The State of Texas, Appellants, v. American Airlines, Inc., Appellee.

Appellee’s Unopposed Motion to Extend Time to File Response Brief Mary A. McNulty State Bar No. 13839680 [email protected] Leonora Meyercord State Bar No. 24074711 [email protected] J. Meghan McCaig State Bar No. 24070083 [email protected] Richard B. Phillips, Jr. State Bar No. 24032833 [email protected] Holland & Knight LLP 1722 Routh Street, Suite 1500 Dallas, Texas 75201 214-964-9500 Fax: 214-964-9501 Counsel for Appellee To the Honorable Court of Appeals: 1. Under Texas Rules of Appellate Procedure 2, 10.5(b), and 38.6(d), Appellee American Airlines, Inc. respectfully requests a 30-day extension of time to file its response brief.

2. This is an appeal of a final judgment following a bench trial. After obtaining a 30-day extension, the appellant filed his opening brief on February 5, 2025.

Appellee’s response brief is therefore currently due on Friday, March 7, 2025. The requested extension would make the brief due on Monday, April 7, 2025. 1 This is Appellee’s first request for an extension of time to file its response brief.

3. Counsel for the Appellant has stated that the Appellant is not opposed to the requested extension.

4. Appellee requests this extension for two primary reasons. First, J. Meghan McCaig, who tried the case in the trial court, will be leaving Holland & Knight LLP and will not be available to assist with the appellate briefing. 2 Richard B. Phillips, Jr., who will have primary responsibility for drafting the response brief, will need additional time to get up to speed on the record and the issues in this case.

Because the 30th day from March 7, 2025 falls on Sunday, April 6, the deadline would be automatically extended to Monday, April 7. See Tex. R. App. P. 4.1(a).

A motion from Ms. McCaig to withdraw as counsel is forthcoming.

Appellees’ Unopposed Motion to Extend Time to File Response Brief—Page 1 5. Second, Appellee’s counsel has been and will be occupied with other matters that will prevent them from preparing the brief for filing by the current due date. Specifically, counsel has been and will be occupied with the following matters, among others: (a) preparing for and presenting oral argument on February 6, 2025, in No. 24- 60240, Sirius Solutions, LLLP v. Commissioner, pending in the United States Court of Appeals for the Fifth Circuit; (b) assisting with post-trial proceedings in No. 2:21-cv-03955-MMB, Cockerill, et al. v. Corteva, Inc., pending in the United States District Court for the Eastern District of Pennsylvania; (c) assisting with pretrial proceedings and dispositive motions in No. DC-23- 05928, Daniels, et al. v. Yummy Transport, LLC, et al., pending in the 116th District Court, Dallas County, Texas; (d) assisting with post-trial briefing and preparing for the appeal in No. 17564- PC, In re Estate of Kling and No. 489-G, In re Guardianship of Kling, pending in the County Court at Law No. 1, Brazos County, Texas; (e) preparing expert disclosures due on February 21, 2025, in No. 3:22-cv-515- N, Exxon Mobil Corporation v. United States, pending in the United States District Court for the Northern District of Texas; (f) preparing responses to and preparing for a hearing held on February 17, 2025, in No. 2020-0295-E, In re Estate of Long, pending in County Court at Law No. 2, Gregg County, Texas; (g) preparing the appellants’ reply brief filed on February 18, 2025, in No. 06- 24-00064-CV, In re Estate of Long, pending in the Court of Appeals for the Sixth District of Texas at Texarkana; and (h) preparing for oral argument scheduled for March 6, 2025, in No. 12-24- 00247-CV, Southern Cornerstone, Inc. v. Crown Colony Improvement

Appellee’s Unopposed Motion to Extend Time to File Response Brief—Page 2 Association, Inc., pending in the Court of Appeals for the Twelfth District of Texas at Tyler.

6. Additionally, Mr. Phillips is scheduled to be out of the office on March 7, 2025, to attend a meeting of the Texas Supreme Court Advisory Committee.

Wherefore, the Appellee respectfully request that the Court extend the deadline for its response brief to Monday, April 7, 2025. Appellee further requests general relief.

Appellee’s Unopposed Motion to Extend Time to File Response Brief—Page 3 Dated: February 20, 2025 Respectfully submitted, Holland & Knight LLP By: /s/ Richard B. Phillips, Jr. Mary A. McNulty State Bar No. 13839680 [email protected] Leonora Meyercord State Bar No. 24074711 [email protected] J. Meghan McCaig State Bar No. 24070083 [email protected] Richard B. Phillips, Jr. State Bar No. 24032833 [email protected] One Arts Plaza 1722 Routh Street, Suite 1500 Dallas, Texas 75201 214-964-9500 Fax: 214-964-9501 Counsel for Appellee

Appellee’s Unopposed Motion to Extend Time to File Response Brief—Page 4 Certificate of Conference On February 18, 2025, I discussed this motion with Deborah Rao, counsel for Appellant by email. Ms. Rao indicated that Appellant is not opposed to the requested extension.

/s/ Richard B. Phillips, Jr. Richard B. Phillips, Jr.

Appellee’s Unopposed Motion to Extend Time to File Response Brief—Page 5 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.

Richard Phillips on behalf of Richard Phillips Jr. Bar No. 24032833 [email protected] Envelope ID: 97617570 Filing Code Description: Motion Filing Description: Appellee's Unopposed Motion to Extend Time to File Response Brief Status as of 2/20/2025 4:01 PM CST Associated Case Party: GLENN HEGAR COMPTROLLER Name BarNumber Email TimestampSubmitted Status Ray Langenberg 11911200 [email protected] 2/20/2025 3:53:34 PM SENT Kyle PierceCounce [email protected] 2/20/2025 3:53:34 PM SENT Deborah Rao [email protected] 2/20/2025 3:53:34 PM SENT Alyson “Ally” Thompson [email protected] 2/20/2025 3:53:34 PM SENT

Associated Case Party: AMERICAN AIRLINES, INC Name BarNumber Email TimestampSubmitted Status Richard Phillips 24032833 [email protected] 2/20/2025 3:53:34 PM SENT Leonora Meyercord 24074711 [email protected] 2/20/2025 3:53:34 PM SENT Mary McNulty 13839680 [email protected] 2/20/2025 3:53:34 PM SENT Meghan McCaig [email protected] 2/20/2025 3:53:34 PM SENT