Pleasanton Housing Finance Corporation and the Board Members of the Pleasanton Housing Finance Corporation, in Their Official Capacities v. City of Missouri City, Texas & Sienna Parks & Levee Improvement District

ACCEPTED 15-25-00113-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 7/15/2025 6:11 PM No. 15-25-00113-CV CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS IN THE FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 7/15/2025 6:11:23 PM AUSTIN, TEXAS CHRISTOPHER A. PRINE Clerk

PLEASANTON HOUSING FINANCE CORPORATION, AND THE BOARD MEMBERS OF THE PLEASANTON HOUSING FINANCE CORPORATION, IN THEIR CAPACITIES APPELLANTS, V. CITY OF MISSOURI CITY, TEXAS, & SIENNA PARKS & LEVEE IMPROVEMENT DISTRICT APPELLEE.

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ OPENING BRIEF

From the 240th District Court, Fort Bend County, Texas Cause No. 25-DCV-328899 Hon. Surendran K. Pattel, presiding

Blake W. Stribling Texas Bar No. 24070691 [email protected] Daniel J. Decavalier Texas Bar No. 24129028 [email protected] CHASNOFF | STRIBLING, LLP 1020 N.E. Loop 410, Suite 150 San Antonio, Texas 78209 Telephone: (210) 469-4155

Counsel for Pleasonton Housing Finance Corporation and Their Board Members TO THE HONORABLE COURT OF APPEALS:

Pursuant to Texas Rules of Appellate Procedure 10.5(b) and

38.6(d), Appellants in the above-referenced matter file this unopposed motion for extension of time to file Appellants’ opening briefs. Appellants’ opening briefs are currently due July 23, 2025. Appellants respectfully request a 30-day extension, until and including August 22, 2025. This is

Appellants’ first request for an extension of time to file their opening briefs.

I. Current Deadline

This appeal is from an interlocutory order entered by the 240th

District Court of Fort Bend County, in cause number 25-DCV-328899. The

Clerk’s Record was filed July 1, 2025, and the Reporter’s Record was filed

July 3, 2025. Therefore, Appellants’ opening briefs are currently due on

July 23, 2025.

II. Reasons for Extension

This is Appellants’ first request for an extension of time to file their opening briefs. Appellants seek this extension due to conflicts with its counsel’s substantial engagement in other matters with pressing deadlines, commitments, and ongoing work, including the following:

• City of Carrolton, Texas v. Pecos Housing Finance Corporation, et al., Case No. DC-25-07935, pending in the 101st District Court of Dallas County: Hearing on Application for Temporary Restraining Order and Injunctive Relief: July 18, 2025 • Town of Little Elm, Texas v. Pleasanton Housing Finance Corporation, et al., Cause No. 25-5634-367, pending in the 367th District Court of Denton County: Plea to Jurisdiction, Motion to Transfer and Original Answer: July 18, 2025 • City of San Marcos, et al. v. Pecos Housing Finance Corporation, et al., Case No. 25-1185-DCB, pending in the 207th District Court of Hays County: Response to Plaintiff’s Motion for Summary Judgment: July 21, 2025 • City of Crowley, Texas v. Maverick County Housing Finance Corporation, et al., Case No. 236-366467-25, pending in the 236th District Court of Tarrant County: Temporary Injunction Hearing: July 22, 2025 • Wise County Appraisal District; Protests to Notice of Denials: July 23, 2025 • City of Lewisville, Texas v. Cameron County Housing Finance Corporation, et al., Case No. 25-4665-367, pending in the 367th District Court, Denton County: Hearing on Entry of Order: July 24, 2025 • Dallas Central Appraisal District; Response to Requests for More Information; July 25, 2025 • City of Burleson, Texas and City of Cleburne, Texas v. Pecos Housing Finance Corporation, et al.; pending in the 18th District Court of Johnson County: Temporary Injunction Hearing: July 25, 2025 • City of San Marcos, et al. v. Pecos Housing Finance Corporation, et al., Case No. 25-1185-DCB, pending in the 207th District Court of Hays County: Motion for Summary Judgment Hearing: July 28, 2025 • Harris County Municipal Utility District No. 390 v. Pleasanton Housing Finance Corporation, et al., pending in the 165th District Court of Harris County: Response to Request for Production and First Set of Interrogatories: July 28, 2025 • Michael Pottorff, et al. v. Leo Degeest, et al.; pending in the 345th District Court of Travis County, Dispositive Motion and Pleas: July 28, 2025

III. No Opposition Appellees do not oppose the requested extension. This extension of time is sought so that justice may be done in the disposition of this case and is not sought for purposes of delay.

PRAYER

For these reasons, Appellants respectfully request that this Motion for Extension of Time be granted and that the Court extend the time for filing their opening briefs until and including August 22, 2025. Appellants further request all such other relief to which they may be justly entitled.

Dated: July 15, 2025 __/s/ Blake Stribling_____________ Blake W. Stribling Texas Bar No. 24070691 [email protected] Daniel J. Lecavalier Texas Bar No. 24129028 [email protected] CHASNOFF STRIBLING, LLP 1020 N.E. Loop 410, Suite 150 San Antonio, Texas 78209 Telephone: (210) 469-4155

Counsel for Appellants Pleasonton Housing Finance Corporation and their Board Members

CERTIFICATE OF CONFERENCE

I certify that, on July 15, 2025, I conferred with Appellees’ counsel, who stated Appellees are unopposed to the relief requested.

/s/ Blake Stribling Blake Stribling CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing instrument was forwarded to all counsel of record in accordance with the

Texas Rules of Appellate Procedure on July 15, 2025.

/s/ Blake Stribling Blake Stribling 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.

Rachel Feltner on behalf of Blake Stribling Bar No. 24070691 [email protected] Envelope ID: 103176388 Filing Code Description: Motion Filing Description: Unopposed Motion for Extension of Time to File Appellants' Opening Brief Status as of 7/16/2025 7:04 AM CST Associated Case Party: City of Missouri City, Texas Name BarNumber Email TimestampSubmitted Status John Hightower 9614200 [email protected] 7/15/2025 6:11:23 PM SENT Allison Killian 24099785 [email protected] 7/15/2025 6:11:23 PM SENT E. Joyce Iyamu [email protected] 7/15/2025 6:11:23 PM SENT Jordan Marget 24130447 [email protected] 7/15/2025 6:11:23 PM SENT

Associated Case Party: Sienna Parks & Levee Improvement District Name BarNumber Email TimestampSubmitted Status Joel Cleveland 24074042 [email protected] 7/15/2025 6:11:23 PM SENT Joel Cleveland [email protected] 7/15/2025 6:11:23 PM SENT

Case Contacts Name BarNumber Email TimestampSubmitted Status Blake Stribling [email protected] 7/15/2025 6:11:23 PM SENT Kim Decker [email protected] 7/15/2025 6:11:23 PM SENT Rachel Feltner [email protected] 7/15/2025 6:11:23 PM SENT Christopher Schluter [email protected] 7/15/2025 6:11:23 PM SENT Daniel Lecavalier [email protected] 7/15/2025 6:11:23 PM SENT Julie Whitson [email protected] 7/15/2025 6:11:23 PM SENT