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 April 7, 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 4/7/2025 3:51 PM No. 15-24-00111-CV CHRISTOPHER A. PRINE CLERK In the Court of Appeals for the Fifteenth Judicial District Austin, Texas 4/7/2025 3:51:30 PM CHRISTOPHE A. PRINE

Glenn Hegar, Comptroller of Public Accounts of the State of Texas, and Ken Paxton, Attorney General of the State of Texas Appellants, FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS V. 4/7/2025 3:51:30 PM Championx, LLC, CHRISTOPHER A. PRINE Clerk Appellees.

On Appeal from the 419th Judicial District Court, Travis County, Texas Cause Number D-1-GN-20-000139

Appellants’ Unopposed First Motion for Extension of Time to File Appellants’ Reply Brief KEN PAXTON Attorney General KELSEY HANSON Assistant Attorney General BRENT WEBSTER State Bar No. 24096654 First Assistant Attorney General [email protected] RALPH MOLINA Deputy First Assistant Attorney Office of the Attorney General General Tax Litigation Division P.O. Box 12548 (MC 029) AUSTIN KINGHORN Austin, Texas 78711-2548 Deputy Attorney General for Civil Tel: 512-463-8897 Litigation Fax: 512-478-4013 STEVEN ROBINSON Division Chief, Tax Litigation Counsel for Appellants Division MOTION TO EXTEND 1. Appellants ask the Court to grant an extension of fourteen (14) days to file their brief, extending the due date from April 16, 2025, to April 30, 2025.

2. This is Appellants’ first request for an extension of time to file their reply brief.

3. Good cause exists for the Court to grant this extension.

4. The undersigned counsel, Kelsey Hanson, (1) must prepare for and attend a hearing setting for Cause No. D-1-GN-15-003797 in Travis County District Court on April 14, 2025; (2) must prepare for and attend a hearing setting for Cause No. D-1-GN-23-000226 in Travis County District Court on April 15, 2025; and (3) has preparations to make for a five day bench trial setting for Cause No. D-1-GN-15-003797 in Travis County District Court beginning on June 9, 2025.

5. Due to these reasons and other time constraints, Appellants require additional time to submit their Appellants’ Reply Brief.

6. This extension is not being sought for purposes of delay but so that justice may be done.

7. The undersigned counsel conferred with Ms. Antoinette Ellison, counsel for Appellees, on April 4, 2025, and April 7, 2025. On April 7, 2025, Ms. Antoinette Ellison indicated that Appellees are unopposed to Appellants’ request for a 14-day extension of the due date for Appellants’ Reply Brief.

8. All facts recited in this motion are within the personal knowledge of the undersigned counsel, so no verification is necessary under Texas Rule of Appellate Procedure 10.2.

PRAYER Appellants request that this motion be granted, extending the time for filing Appellants’ Reply Brief to April 30, 2025.

KEN PAXTON Attorney General /s/ Kelsey Hanson BRENT WEBSTER KELSEY HANSON First Assistant Attorney Assistant Attorney General General State Bar No. 24096654 RALPH MOLINA [email protected] Deputy First Assistant Attorney General Texas Office of the Attorney General AUSTIN KINGHORN Tax Litigation Division MC 029 Deputy Attorney General for P.O. Box 12548 Civil Litigation Austin, Texas 78711-2548 STEVEN ROBINSON Tel: (512)-463-8897 Division Chief, Tax Litigation Fax: (512) 478-4013 Division Counsel for Appellants

CERTIFICATE OF CONFERENCE Kelsey Hanson conferred with Antoinette Ellison, counsel for Appellee, by email on April 4, 2025, and April 7, 2025. Appellees are unopposed to this motion.

/s/ Kelsey Hanson KELSEY HANSON Assistant Attorney General

CERTIFICATE OF SERVICE I certify that on April 7, 2025, a copy of the foregoing pleading was served on all parties or attorneys of record via the service methods listed below.

Via Electronic Service and/or email: Deborah S. Sloan [email protected] JONES DAY 2727 N. Harwood Street, Suite 500 Dallas, Texas 75201-1515 John M. Allen [email protected] Antoinette L. Ellison [email protected] JONES DAY 1221 Peachtree Street NE Atlanta, Georgia 30361 ATTORNEYS FOR APPELLEES

/s/ Kelsey Hanson KELSEY HANSON Assistant Attorney General

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.

Michelle Elkins on behalf of Kelsey Hanson Bar No. 24096654 [email protected] Envelope ID: 99371310 Filing Code Description: Motion Filing Description: Appellants First MTE for Reply Brief Status as of 4/7/2025 4:03 PM CST Associated Case Party: ChampionX, LLC Name BarNumber Email TimestampSubmitted Status Deborah Sloan 786230 [email protected] 4/7/2025 3:51:30 PM SENT Carla Dennis [email protected] 4/7/2025 3:51:30 PM SENT John MAllan [email protected] 4/7/2025 3:51:30 PM SENT Antoinette L.Ellison [email protected] 4/7/2025 3:51:30 PM SENT

Associated Case Party: Ken Paxton, Attorney General of the State of Texas Name BarNumber Email TimestampSubmitted Status Kelsey Hanson 24096654 [email protected] 4/7/2025 3:51:30 PM SENT

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