Public Utility Commission of Texas // City of Denton Operating as Denton Municipal Electric v. City of Denton Operating as Denton Municipal Electric // Cross-Appellee Public Utility Commission of Texas

ACCEPTED 15-25-00018-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 5/23/2025 9:26 AM NO. 15-25-00018-CV CHRISTOPHER A. PRINE CLERK IN THE COURT OF APPEALS FILED IN 15th COURT OF APPEALS FOR THE FIFTEENTH JUDICIAL DISTRICTAUSTIN, TEXAS AT AUSTIN, TEXAS 5/23/2025 9:26:17 AM CHRISTOPHER A. PRINE Clerk PUBLIC UTILITY COMMISSION OF TEXAS, Appellant/Cross-Appellee, v. CITY OF DENTON, OPERATING AS DENTON MUNICIPAL ELECTRIC, Appellee/Cross-Appellant.

On Appeal from the 459th Judicial Court, Travis County, Texas Cause No. D-1-GN-23-008974 JOINT MOTION FOR EXTENSION OF TIME

Appellant/Cross-Appellee Public Utility Commission of Texas (“PUC”) and Appellee/Cross Appellant City of Denton, Operating as Denton Municipal Electric (“DME”) jointly move for extension of time to file the briefing in in opposition to their cross-appeals before this Court.

1. The PUC and DME both filed their initial briefs in support of their appeals on May 14, 2025. The Response Briefs are currently due on or before June 13, 2025.

2. The Parties seek a 30-day extension of time to file Response Brief, which would make the Brief due on or before July 14, 2025.

3. This extension of time is necessary because of competing deadlines and scheduling conflicts in other matters. Specifically, DME’s lead counsel has appellate briefs in two different matters due on May 27, 2025, in the appeals styled Aranas County, Texas v. Western Steel Co., Case No. 13-25-00148-CV and Aransas County, Texas v. NorthStar Recovery Services, Inc. Case No. 13-25-00159-CV before the Thirteenth Court of Appeals in Corpus Christi Texas.

The same day, counsel has an all-day mediation in ES3 Minerals, LLC v. Nicholas Kreines, et al., Cause No. 24-BC03B-0005, Third Division of the Texas Business Court, and is preparing mediation materials and briefing in advance of the mediation in an effort to resolve the dispute.

Finally, counsel has a jury trial set to begin June 9, 2025, in Chandra Ervin v. City of Austin, Case No. 1:23-cv-1113-ML (Western District of Texas, Austin Division).

4. Counsel for the PUC also has scheduling conflicts in other matters, specifically, two briefs due on June 13, 2025, in the two related cases styled TCCI Ponder Farms 2021, LLC v. Public Utility Commission of Texas, Cause No. D-1-GN-24-010011 (250th Judicial District Court, Travis County, Texas), and TCCI Range-Mead 2021, LLC v. Public Utility Commission of Texas, Cause No. D-1-GN-24-008563 (459th Judicial District Court, Travis County, Texas).

5. This request for extension is not brought for purposes of delay, but so that justice may be done, and so the matters at issue may be fully and appropriately briefed for the Court.

For these reasons, the Parties request that this Court grant the Joint Motion for Extension of Time to File their respective Response Briefs, so that the Briefs will be due on or before July 14, 2025. The Parties also request any other relief to which they may be entitled.

Respectfully submitted, LLOYD GOSSELINK OFFICE OF THE ATTORNEY ROCHELLE & TOWNSEND, P.C. GENERAL OF TEXAS – Congress Avenue, Suite 1900 ENVIRONMENTAL Austin, Texas 78701 PROTECTION DIVISION (512) 322-5800 Phone P.O. Box 12548 (MC-066) (512) 472-0532 Facsimile Austin, Texas 78711-2548 (512) 463-2012 Phone By: /s/ Jose E. de la Fuente (512) 320-0911 Facsimile JOSE E. de la FUENTE State Bar No. 00793605 By: /s/ Jordan Pratt [email protected] JOHN R. HULME GABRIELLE C. SMITH State Bar No. 24093172 State Bar No. 10258400 [email protected] [email protected] JAMIE L. MAULDIN JORDAN PRATT State Bar No. 24065694 State Bar No. 24140277 [email protected] [email protected] ROSLYN M. WARNER State Bar No. 24117520 ATTORNEYS FOR APPELLANT / [email protected] CROSS-APPELLEE ATTORNEYS FOR APPELLEE / CROSS-APPELLANT

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Cathy Daniels on behalf of Jose de la Fuente Bar No. 00793605 [email protected] Envelope ID: 101196449 Filing Code Description: Motion Filing Description: JOINT MOTION FOR EXTENSION OF TIME Status as of 5/23/2025 9:29 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Katherine Coleman 24059596 [email protected] 5/23/2025 9:26:17 AM SENT Jamie Mauldin 24065694 [email protected] 5/23/2025 9:26:17 AM SENT Gabrielle Smith 24093172 [email protected] 5/23/2025 9:26:17 AM SENT David Laurent [email protected] 5/23/2025 9:26:17 AM SENT John RHulme [email protected] 5/23/2025 9:26:17 AM SENT Jose E.de la Fuente [email protected] 5/23/2025 9:26:17 AM SENT Amy Hoffee [email protected] 5/23/2025 9:26:17 AM SENT Chris Ekoh [email protected] 5/23/2025 9:26:17 AM SENT Justin Swearingen [email protected] 5/23/2025 9:26:17 AM SENT Jordan Pratt [email protected] 5/23/2025 9:26:17 AM SENT Colton Halter [email protected] 5/23/2025 9:26:17 AM SENT John Hubbard [email protected] 5/23/2025 9:26:17 AM SENT Christiana Segura 24143396 [email protected] 5/23/2025 9:26:17 AM SENT Roslyn Warner [email protected] 5/23/2025 9:26:17 AM SENT Devin Alexander [email protected] 5/23/2025 9:26:17 AM SENT Michael McMillin [email protected] 5/23/2025 9:26:17 AM SENT Sharbel Sfeir [email protected] 5/23/2025 9:26:17 AM SENT Marcella Lunn [email protected] 5/23/2025 9:26:17 AM SENT