2020 Long Tail Trail Investments, LLC v. State of Texas, Attorney General Kenneth Paxton (In His Official Capacity), Texas Comptroller of Public Accounts Glenn Hegar (In His Official Capacity), and the Office of the Texas Comptroller of Public Accounts

ACCEPTED 15-25-00086-Cv FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 7/17/2025 8:02 AM CHRISTOPHER A. PRINE CLERK Cause No. 15-25-00086 CV FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS 7/17/2025 8:02:28 AM IN THE COURT OF APPEALS CHRISTOPHER A. PRINE Clerk THIRTEENTH JUDICIAL DISTRICT OF AUSTIN TEXAS

City of Grand Prairie, et al., Appellants-Plaintiffs, City of Brownsville, et al., Appellants – Intervenor Plaintiffs, Long Tail Trail Investments, LLC, Appellant – Intervenor Plaintiff, v. The State of Texas, et al., Appellant Defendants.

On appeal from the 261st District Court of Travis County, Texas No. D-1-GN-23-007785, the Honorable Maria Cantú Hexsel presiding

FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF BY APPELLANT – INTERVENOR PLAINITFF CITY OF BROWNSVILLE

MAY IT PLEASE THE COURT: The City of Brownsville, Appellant – Intervenor Plaintiff, respectfully requests a 30-day extension of time to file its opening brief pursuant to Texas Rules of Appellate Procedure 10.5(b), and in support thereof respectfully shows: 1. City of Brownsville filed a notice of appeal in the district court on June 6, 2025.

2. City of Brownsville’s opening brief was due on July 16, 2025.

3. City of Brownsville seeks an additional 30 days, through and until Friday, August 15, 2025, to file its opening brief.

4. City of Brownsville seeks an extension so that the briefing deadlines for all Appellant-Parties will be aligned and so that counsel for City of Brownsville may have adequate time to prepare the brief.

5. This Honorable Court has granted 30-day extensions to other Appellant- Parties. The requested additional time will facilitate necessary consultation between City of Brownsville and counsel, review of the record, and preparation of an opening brief that will most effectively assist the Court in its resolution of this appeal. The undersigned’s personal and professional obligations also spur this request.

6. This is City of Brownsville’s first request for an extension of time.

7. The other parties to this action have indicated that they are unopposed to this request for extension.

8. This extension is not sought for delay, but so that justice may be done.

City of Brownsville respectfully requests an extension of 30 days from the original filing deadline to file its opening brief, through and until Friday, August 15, 2025.

Respectfully submitted,

CITY OF BROWNSVILLE GUILLERMO “WILL” TREVIÑO CITY ATTORNEY State Bar No. 24044743 [email protected] [email protected] (956) 548 – 6070 1001 East Elizabeth Street Brownsville, Texas 78520 /s/ Lena Chaisson-Muñoz ________________ ___________________ Lena Chaisson-Muñoz Assistant City Attorney State Bar No. 24085244 [email protected] Jennifer Avendaño First Assistant City Attorney State Bar No. 24052304 [email protected] Criselda Rincon-Flores Assistant City Attorney State Bar No. 24049412 [email protected]

CERTIFICATE OF SERVICE I certify that on June 27, 2025, the parties electronically conferred regarding extensions of time to file openings briefs, and none were opposed. /s/ Lena Chaisson-Muñoz ____________________ Lena Chaisson-Muñoz

CERTIFICATE OF SERVICE I certify that on July 16, 2025, a true and correct copy of this Motion have been submit to all attorneys of record via e-mail and/or electronic filing service of process.

/s/ Lena Chaisson-Muñoz ____________________ Lena Chaisson-Muñoz 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.

Lena Chaisson-Muñoz on behalf of Lena Chaisson-Munoz Bar No. 24085244 [email protected] Envelope ID: 103240515 Filing Code Description: Motion Filing Description: Motion for Extension of Time to File Opening Brief by City of Brownsville Status as of 7/17/2025 8:07 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Allison Collins 24127467 [email protected] 7/17/2025 8:02:28 AM SENT Lena Chaisson-Munoz [email protected] 7/17/2025 8:02:28 AM SENT Raymond Abarca [email protected] 7/17/2025 8:02:28 AM SENT Cole Wilson [email protected] 7/17/2025 8:02:28 AM SENT Will S.Trevino [email protected] 7/17/2025 8:02:28 AM SENT Sherry Brown [email protected] 7/17/2025 8:02:28 AM SENT Andy Messer [email protected] 7/17/2025 8:02:28 AM SENT Brad Bullock [email protected] 7/17/2025 8:02:28 AM SENT Timothy Dunn [email protected] 7/17/2025 8:02:28 AM SENT Todd Disher [email protected] 7/17/2025 8:02:28 AM SENT William Thompson [email protected] 7/17/2025 8:02:28 AM SENT Cole Wilson [email protected] 7/17/2025 8:02:28 AM SENT Guillermo Trevino [email protected] 7/17/2025 8:02:28 AM SENT Lena Chaisson-Munoz [email protected] 7/17/2025 8:02:28 AM SENT George Hyde [email protected] 7/17/2025 8:02:28 AM SENT Matthew Weston [email protected] 7/17/2025 8:02:28 AM SENT David Overcash [email protected] 7/17/2025 8:02:28 AM SENT Clark McCoy [email protected] 7/17/2025 8:02:28 AM SENT