State of Texas, the Texas Facilities Commission, the Texas Health and Human Services Commission, Mike Novak, in His Official Capacity as Executive Director of the TFC, and Rolland Niles, in His Official Capacity as Deputy Executive Commissioner for the System Support Services Division of the Texas Health and Human Services Commission v. Broadmoor Austin Associates, a Texas Joint Venture

ACCEPTED 15-25-00013-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 3/28/2025 10:04 AM No. 15-25-00013-CV CHRISTOPHER A. PRINE CLERK In the Fifteenth Court of Appeals FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS Austin, Texas 3/28/2025 10:04:51 AM CHRISTOPHER A. PRINE Clerk The State of Texas, et al., Appellants, v. Broadmoor Austin Associates, a Texas joint venture, Appellee.

On Appeal from the 455th Judicial District of Travis County, No. D-1-GN-23-007899 Unopposed Motion for Extension of time to File Appellee’s Brief

1. Appellee Broadmoor Austin Associates asks the Court to grant it a 30- day extension of time to file the Brief of Appellee in this appeal.

2. The current due date is April 7, 2025. The new due date would be May 7, 2025.

3. Appellee does not seek this extension for delay.

4. This is the first extension Appellee has sought for its brief.

5. Appellants do not oppose this extension.

6. The following grounds provide additional good cause for extending the time to file the Appellee’s brief: • Lead appellate counsel for Appellee is new to this case and an ex- tension would allow sufficient time to review the record from the proceedings below and address the issues on appeal. • Lead appellate counsel for Appellee has been and continues to be engaged in other litigation with significant time commitments that make it impracticable to complete Appellee’s brief by the current deadline, including preparing a petition for rehearing en banc in Attia v. Oura Ring, Inc., No. 24-2622 (9th Cir.), currently due April 4; preparing a plea to the jurisdiction in a matter in which counsel has not yet appeared; and preparing a response to a petition for a writ of mandamus in a case in counsel has not yet appeared. • Additional counsel for Appellee have likewise been engaged in other litigation with significant time commitments, including preparation for trial set for March 24 but ultimately continued in CW Park Oaks, LLC v. Bexar Appraisal District, No. 2023-CI- 15912 (37th Dist. Ct. Bexar Cnty.); taking depositions and prepar- ing various discovery filings during the weeks March 24 and March 31 Summit Sky Advisory, LLC v. Eastern Airlines, LLC, No. 1:23-CV-1332 (W.D. Tex.); and preparing for a trial set for April 7, in Forest Oaks Living, LLC v. Bexar Appraisal District, No. 2023-CI-15777 (224th Dist. Ct. Bexar Cnty.).

Conclusion and Prayer For these reasons, Appellee requests a 30-day extension of time to file Appel- lee’s Brief, to May 7, 2025.

Respectfully submitted, Scott Douglass & McConnico LLP

Jason R. LaFond State Bar No. 24103136 Colorado Street, Suite 2400 Austin, Texas 78701 (512) 495-6300 [email protected] Counsel for Appellee

Certificate of Conference I certify that on March 28, 2025, I conferred by e-mail with Alyssa Bixby-Law- son, counsel for Appellants, who represented that Appellants does not oppose the relief sought through this motion.

Jason R. LaFond

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.

Michaelle Peters on behalf of Jason LaFond Bar No. 24103136 [email protected] Envelope ID: 99005269 Filing Code Description: Motion Filing Description: Unopposed Motion for Extension of Time to File Appellee's Brief Status as of 3/28/2025 10:09 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Michaelle Peters [email protected] 3/28/2025 10:04:51 AM SENT Angela Goldberg [email protected] 3/28/2025 10:04:51 AM SENT Susie Smith [email protected] 3/28/2025 10:04:51 AM SENT Jason R.LaFond [email protected] 3/28/2025 10:04:51 AM SENT Kemp Kasling [email protected] 3/28/2025 10:04:51 AM SENT Angie Espinoza [email protected] 3/28/2025 10:04:51 AM SENT

Associated Case Party: State of Texas Name BarNumber Email TimestampSubmitted Status Victoria Gomez [email protected] 3/28/2025 10:04:51 AM SENT Alyssa Bixby-Lawson [email protected] 3/28/2025 10:04:51 AM SENT

Associated Case Party: Broadmoor Austin Associates, a Texas Joint Venture Name BarNumber Email TimestampSubmitted Status Sara W.Clark [email protected] 3/28/2025 10:04:51 AM SENT Casey Dobson [email protected] 3/28/2025 10:04:51 AM SENT