All Star Imports, Inc. D/B/A World Car Mazda North// Mazda Motor of North America, Inc. A/K/A Mazda Motor of America, Inc. v. Board of the Texas Department of Motor Vehicles, and Mazda Motor of North America, Inc. A/K/A Mazda Motor of America, Inc.// Cross-Appellee, All Star Imports, Inc. D/B/A World Car Mazda North

ACCEPTED 15-24-00017-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 2/24/2025 10:39 AM No. 15-24-00017-CV CHRISTOPHER A. PRINE CLERK IN THE COURT OF APPEALS FOR THE FIFTEENTH DISTRICT OFILED F TEXAS IN 15th COURT OF APPEALS AUSTIN, TEXAS ALL STAR IMPORTS, INC. D/B/A WORLD CAR MAZDA NORTH 2/24/2025 , 10:39:41 AM CHRISTOPHER A. PRINE Appellant and Cross-Appellee, Clerk v. MAZDA MOTOR OF NORTH AMERICA, INC. A/K/A MAZDA MOTOR OF AMERICA, INC., Cross-Appellant and Appellee, v. BOARD OF THE TEXAS DEPARTMENT OF MOTOR VEHICLES, Appellee and Cross-Appellee.

On Appeal from Cause No. D-1-GN-23-005034 in the 345th Judicial District Court of Travis County, Texas MAZDA’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE CROSS-APPELLEE’S BRIEF

TO THE HONORABLE FIFTEENTH COURT OF APPEALS: Mazda Motor of North America, Inc. a/k/a Mazda Motor Of America, Inc., respectfully files this motion for extension of time to file its cross-appellee’s brief in this case.

A. Mazda’s cross-appellee’s brief to the Board is due on Monday, February 23, 2025.

B. Mazda respectfully requests a three-day extension of time until Thursday, February 27, 2025. Mazda relies on the following facts to show a reasonable explanation for this request:  Mazda’s counsel, Ben Escobar and Jeff Nobles, have had conflicting obligations in a number of other cases since the opposing briefs were filed in this case.

 Counsel has been preparing a combined reply brief to the appellee’s briefs of World Car and the Board in this case.

These briefs are due on Thursday, February 27. The issues in those reply briefs and the cross-appellee’s brief are the same: what is the meaning of “act,” as used in section 2001.146(c) of the Texas Government Code?

 Counsel prepared and filed a reply brief in the Second Court of Appeals on January 28, 2025.

 Counsel prepared and filed a post-submission brief, ordered by the First Court of Appeals on January 28, and filed on February 20, 2025.

 Counsel is revising and finalizing a mandamus petition for filing in the Fourth Court of Appeals on February 24, 2025.

 Counsel has been handling post-mandate judgment enforcement activities in a Dallas County District Court.

 In addition, Nobles and his wife traveled to Boston, Massachusetts, for the wedding shower of their daughter Audrey, on February 2, 2025. He was out of the office on January 31 and February 3.

 Finally, Nobles is in the final stages of preparing for his retirement from his law firm on February 28, 2025. He will continue to practice law at a slower pace after his retirement, but the internal and external planning for this transition has been time-consuming.

 None of these matters has taken precedence over this case, but they involve court settings, briefing deadlines, and personal commitments that could not be rescheduled.

C. There have not been any previous extensions regarding these briefs.

PRAYER For these reasons, appellant respectfully requests a three-day extension of time, until February 27, 2025, for filing its reply briefs.

Respectfully submitted, /s/ Brit T. Brown Brit T. Brown [email protected] Texas Bar No. 03094550 Benjamin A. Escobar, Jr. [email protected] Texas Bar No. 00787440 AKERMAN LLP 1300 Post Oak Blvd., Suite 2300 Houston, Texas 77056- Telephone: (713) 623-0887 Fax: (713) 960-1527 Fax: 713-647-6884

Jeff Nobles [email protected] Texas Bar No. 15053050 HUSCH BLACKWELL LLP Travis Street, Suite 2350 Houston, Texas 77002 Telephone: 713-647-6800 ATTORNEYS FOR APPELLEE/CROSS- APPELLANT, MAZDA MOTOR OF NORTH AMERICA, INC. A/K/A MAZDA MOTOR OF AMERICA, INC.

CERTIFICATE OF CONFERENCE I certify that I have conferred with counsel for All Star Imports, Inc. d/b/a World Car Mazda North. They are unopposed to this motion.

/s/ Jeff Nobles Jeff Nobles

CERTIFICATE OF SERVICE I certify that this document was electronically filed with the Clerk of the Court using the electronic case filing system. A true and correct copy was served on the counsel of record listed below on February 24, 2025: Jeffrey L. Oldham OFFICE OF THE ATTORNEY GENERAL [email protected] Ken Paxton, Attorney General Walter A. Simons Brent Webster [email protected] James Lloyd BRACEWELL LLP Ernest C. Garcia Louisiana St., Ste. 2300 Kathy Johnson Houston, Texas 77002 [email protected] P.O. Box 12548 Jarod R. Stewart Capital Station [email protected] Austin, Texas 78711 Austin Kreitz [email protected] Counsel for Appellee Board of the STEPTOE, LLP Texas Department of Motor Texas Ave., Ste. 2800 Vehicles Houston, Texas 77002 Counsel for Appellant All Star Imports, Inc. d/b/a World Car Mazda North /s/ Jeff Nobles Jeff Nobles

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. darlyn castillo on behalf of Jeffery Taylor Nobles Bar No. 15053050 [email protected] Envelope ID: 97702907 Filing Code Description: Motion Filing Description: Mazda's Unopposed Motion for Extension of Time to File Cross-Appellee's Brief Status as of 2/24/2025 10:58 AM CST Associated Case Party: Board of the Texas Department of Motor Vehicles Name BarNumber Email TimestampSubmitted Status Christian Young [email protected] 2/24/2025 10:39:41 AM SENT Kathy Johnson [email protected] 2/24/2025 10:39:41 AM SENT

Case Contacts Name BarNumber Email TimestampSubmitted Status Benjamin AEscobar [email protected] 2/24/2025 10:39:41 AM SENT Brit T.Brown [email protected] 2/24/2025 10:39:41 AM SENT Neila Olvera [email protected] 2/24/2025 10:39:41 AM SENT Jeffery Nobles 15053050 [email protected] 2/24/2025 10:39:41 AM SENT Jeffrey Oldham 24051132 [email protected] 2/24/2025 10:39:41 AM SENT Walter Simons 24098429 [email protected] 2/24/2025 10:39:41 AM SENT Jarod Stewart 24066147 [email protected] 2/24/2025 10:39:41 AM SENT Austin Kreitz 24102044 [email protected] 2/24/2025 10:39:41 AM SENT Katherine Johnson 24126964 [email protected] 2/24/2025 10:39:41 AM SENT Terri Patton [email protected] 2/24/2025 10:39:41 AM SENT Christina Ramos [email protected] 2/24/2025 10:39:41 AM SENT Sallie Woodell [email protected] 2/24/2025 10:39:41 AM SENT