Ken Paxton, in His Official Capacity as Attorney General for the State of Texas and the Office of the Attorney General for the State of Texas v. Delia Garza, in Her Official Capacity as Travis County Attorney; John Creuzot, in His Official Capacity as Dallas County Criminal District Attorney; And Brian Middleton, in His Official Capacity as District Attorney of Fort Bend County (268th Judicial District)

ACCEPTED 15-25-00116-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 7/11/2025 6:32 PM No. 15-25-00116-CV CHRISTOPHER A. PRINE CLERK FILED IN I N THE F IFTEENTH C OURT OF A PPEALS15th COURT OF APPEALS AUSTIN, TEXAS KEN PAXTON, ET AL . , 7/11/2025 6:32:50 PM CHRISTOPHER A. PRINE Appellants, Clerk v. DELIA GARZA , ET AL . , Appellees.

On Direct Appeal from the 419th Judicial District Court, Travis County, Texas No. D-1-GN-25-003445, Consolidated With No. D-1-GN-25-003531 & No. D-1-GN-25-003581 APPELLEES’ REPLY TO APPELLANTS’ RESPONSE TO APPELLEES’ EMERGENCY MOTION FOR TEMPORARY RELIEF TO THE HONORABLE FIFTEENTH COURT OF APPEALS: Temporary relief is necessary to maintain the status quo while this Court considers Appellants’ appeal. Appellants’ response amounts to a sweeping assertion that his authority is effectively unlimited and that any delay in producing reports (that were never previously sought) somehow constitutes irreparable harm. The Attorney General offers no evidence—none—that a temporary delay will cause any concrete injury, especially when Appellants will be able to obtain the requested reports should they ultimately prevail on this appeal.

By contrast, Appellees face immediate and irreparable harm under the trial court’s detailed findings: hundreds of hours of diverted staff time, disclosure of confidential information, and the threat of removal from office in a quo warranto action. Appellees sought relief just six weeks after the rules took effect, won a temporary injunction after a full evidentiary hearing, and now seek only to preserve the status quo while this Court reviews the temporary injunction order.

The Attorney General claims broad rulemaking power under a statute that says nothing about rules. Appellees are not asking this Court to resolve those questions now but rather before they are required to comply with the Challenged Rules. Appellants’ opening brief is due in 17 days. TEX. R. APP. P. 38.6(a)(2).

This is precisely what temporary appellate relief is for. At this stage, Appellees need not prove they will win—only that Appellees have demonstrated— and the Attorney General has not refuted—that Appellees’ challenge raises serious legal questions and that the equities favor a continued stay. See In re Tex. Educ.

Agency, 619 S.W.3d 679, 683–84 (Tex. 2021).

ARGUMENT Preliminarily, the Attorney General’s assertion that Appellees “manufacture[d] an emergency” instead of “prepar[ing] to comply,” Resp. at 3, is not only irrelevant, it is belied by the record.

Appellees began preparing to comply with the Challenged Rules before they took effect and told the Attorney General that producing the requested reports is extraordinarily burdensome. Evidence presented at the temporary injunction hearing establishes that Appellees already have spent hundreds of hours preparing the requested reports. 2RR74:5-22. Before Appellees requested that the Attorney General agree to temporary relief in this Court, Appellees asked the Attorney General to postpone or extend the reporting deadlines either during the pendency of litigation or until September 1, but he refused. 2RR148:3-7.

Regardless, Appellees would have needed temporary relief from this Court no matter when they filed their lawsuits. Appellees brought suit a mere six weeks after the Challenged Rule took effect on April 2, 2025. Then, after extensive conferral with the Attorney General, they noticed the temporary injunction hearing shortly thereafter. Even had they filed earlier, less than three months between the effective date and due date of the first report would never have been enough time to fully litigate the validity of the rule. And, in the end, it was the Attorney General who waited until 4:00 pm June 27, 2025—the Friday prior to the Monday compliance deadline—to file his notice of appeal.

I. The Attorney General glosses over the Rule 29.3 balancing standard, which prioritizes “preserv[ing] the parties’ rights.”

The Attorney General misapplies the Texas Supreme Court’s balancing test.

Even where “the State has an intrinsic right to enforce its own laws,” In re State, 711 S.W.3d 641, 645 (Tex. 2024) (cleaned up), the balancing of harms is “a required aspect of a court’s effort to preserve the parties’ rights pending appeal.” Id. at (emphasis added). Here, the Attorney General acknowledges Appellees have at least some rights at stake. (E.g., Resp. at 25–26 (the right and responsibility to prosecute cases)).

A temporary injunction applicant “is not required to establish that it will prevail on the final trial.” Butnaru v. Ford Motor Co., 84 S.W.3d 198, 211 (Tex. 2002) (citing Sun Oil Co. v. Whitaker, 424 S.W.2d 216, 218 (Tex. 1968)). And the decision on this motion does not even decide the merits of the temporary injunction—that is what the appeal is for. This is why, in In re State, the Texas Supreme Court made “no definitive statement about the merits” but instead found temporary relief justified when the movant simply “raised serious doubt” about the validity and constitutionality of the actions that the movant sought to stay. 711 S.W.3d at 646.

The balancing of harms between the various parties has two elements that are critical here. First, whether damages or other harm can “feasibly be recouped if it is later determined” that the harmful action was invalid is part of asking whether harms are “irreparable” and thus entitled to additional weight. Id. at 647. Second, when a governmental entity’s constitutional rights are impacted, that is where the “status quo” question is particularly helpful, too—favoring a stay of state action that would change another governmental unit’s “manner of governance” from its “last, actual, peaceable non-contested status” before the lawsuit. Tex. Educ. Agency, S.W.3d at 683–84.

Appellants do not address these factors or even mention In re Texas Education Agency. They are dispositive here, if the traditional balance weighing is not enough.

II. Appellants show no harm and ignore Appellees’ harm.

The balance of harms weighs heavily in Appellees’ favor. At the temporary injunction hearing, Appellees presented substantial evidence that they would be irreparably harmed by compliance with the Challenged Rules, which the Attorney General neither contradicted nor countered. Rather, the Attorney General presents the legally incorrect view that government officials are irreparably harmed whenever they cannot impose their view of the law.

A. The Attorney General has no evidence of harm.

Typically, “[w]hen the State files suit to enjoin ultra vires action by a local official, a showing of likely success on the merits is sufficient to satisfy the irreparable-injury requirement for a temporary injunction.” State v. Hollins, 620 S.W.3d 400, 410 (Tex. 2020). Here, however, Appellees are the government officials bringing an ultra vires action, and Appellees have shown a likelihood of success on the merits, as the district court found. Allowing the Attorney General to invoke this doctrine in defending against an ultra vires claim would shield the Attorney General from ultra vires actions even if he could show a likelihood of success on the merits, which he certainly has not shown. Plus, there has been no violation of law, as the Attorney General has claimed, for which he needs any enforcement. The precise reason that Appellees need the temporary injunction and stay is so that the Attorney cannot injure them in violation of the law.

Simply stated, the burden of having to delay enforcement of a brand-new administrative rule, for which Appellees present a serious challenge, counts for little against the thousands of personnel hours, millions of dollars, and confidential information which the Appellees are poised to lose. Moreover, the Attorney General does nothing to cast doubt on the substantial irreparable injuries that Appellees have demonstrated. Nor did he make any evidentiary record below.

Rather, the Attorney General purports to create his own record on appeal with his claim that “the Montgomery County District Attorney[] has already complied with the initial reporting requirements” to “suggest[] that they are far less burdensome than [Appellees] allege.” Resp. at 3. But Montgomery’s County’s alleged report is not in the record, and Appellees have reason to believe that it is far from complete and identifies many of the same burdens outlined in the testimony by the Appellees, which, of course, is in the record. That is to say, the Attorney General’s reference to an out-of-record report allegedly produced by just one of the thirteen affected counties proves nothing.

B. Appellees showed abundant and unrefuted evidence of harm.

The district court found that Appellees demonstrated irreparable harm including, in addition to interference with their constitutional prosecutorial responsibilities, (1) the expenditure of “a significant amount of resources, personnel time, and taxpayer funds,” which cannot be recovered as damages, and (2) the disclosure of confidential information of various types. CR393.

Appellees’ evidence of harm was presented via many declarations and testimony at the temporary injunction hearing. To give the Court a flavor: Danny Smith of Travis County testified that his team has spent “hundreds of hours just in the last two months” preparing to comply. 2RR74:5-22; see also CR94. “[B]y focusing on [compliance] we are not focusing on what we can be doing for the actual criminal cases that are filed in our office.” 2RR82:24-83:13.

Holly Taylor of Travis County added that “[r]ecently” she “ha[d] dedicated most of [her] working hours to implementing methods for data and document collection and retention to comply with the challenged rules.” So has Williamson County District Attorney Shawn Dick. (Mot. App’x Tab C-19 at § 14.). Amy Lechuga of El Paso County “estimate[d] that accurately completing the initial report will take over 12,000 hours of staff and attorney time,” and that the county would “need to hire, at minimum, one software developer, two secretaries, one attorney, and one functional data analyst permanently on staff.” CR109-10. Marsha Edwards of Dallas County explained that compliance would “divert staff away from their core roles and responsibilities.” CR256. Joshua Reiss declared that Harris County “would have to hire 10 new, fulltime employees dedicated to a specialized ‘OAG Reporting Unit,’” CR272, at an “initial cost . . . in excess of $11 million over the next five years,” CR272-73. Jamissa Jarmon explained that Bexar County would hire a third-party contractor because Bexar County’s IT department lacks “the capacity, software, or personnel to review and search through such a large volume of emails.” CR265-266. Fort Bend County would likely do the same thing. (Tab C- at §§ 15–16.) Williamson County already has hired an outside contractor. (Tab C-19 at § 14.)1 The same evidence demonstrates that Appellees would be irreparably injured by the forced disclosure of legally protected confidential information. Holly Taylor specified the categories of confidential information “that [are] commonly found in [case] files” including “victim contact information, statements, and pseudonyms; DNA testing of rape kits; graphic photos; grand jury testimony; identities of confidential informants; criminal history information; mental health and substance abuse treatment records; CPS records; and defense counsel’s confidential communications with prosecutors.” CR100. Alma Trejo provided a very similar list.

CR105-06. Joshua Reiss stated “federal agencies will disapprove” of certain required disclosures. CR275. The District Attorneys for Williamson and Fort Bend Counties also expressed legal and ethical reservations of turning over materials protected by existing federal and state laws. (Tab C-19 at § 8; Tab C-18 at § 12.).

III. As the trial court found, Appellees raise serious questions concerning the validity of the Challenged Rules.

Discussion of the merits here is necessarily abbreviated, given the procedural posture. But the Attorney General’s merits discussion is wrong in several ways.

A. The Attorney General lacks the authority to adopt the Challenged Rules.

The Attorney General acknowledges, as he must, that an agency rule is invalid if the agency was not given authority to adopt the rule. See Response at 9.

However, he claims that Section 41.006 provides him with either express or implied rulemaking authority. Neither is true.

The Attorney General first argues that Section 41.006 “sounds suspiciously like an express grant of authority.” Id. at 9. But sounding “like” an express grant of authority (whatever that means) is not an express grant of authority. There is no question that Section 41.006 says nothing about adopting rules or engaging in rulemaking, unlike the 20+ statutes that expressly authorize the Attorney General to do so in discrete areas by using clear, unmistakable language. The Texas legislature knows how to confer rulemaking authority on the Attorney General when it wants to do so. It chose not to do so here. “[E]very word excluded from a statute must also be presumed to have been excluded for a purpose.” Cameron v. Terrell & Garrett, Inc., 618 S.W.2d 535, 540 (Tex. 1981).

The Attorney General argues, next, that “even if the statutory language did not confer an express grant of rulemaking authority, there can be little question that such rulemaking authority is implied.” Response at 9. As administrative law professor Ron Beal explains in his amicus brief, no court in Texas has ever held that an agency may adopt a rule when the agency was not given express rulemaking authority. See R. Beal’s Amicus at 5.

The Attorney General cites Pruett v. Harris County Bail Bond Board, 249 S.W.3d 447, 452 (2008) for implied rulemaking authority. See Response at 9-10. But Pruett is an express rulemaking authority case (like all other such cases). The enabling statute in Pruett authorized the government agency to “‘adopt and post rules necessary to implement this chapter.’” 249 S.W.3d 447, 453 (Tex. 2008) (emphasis added). The Attorney General misconstrues Pruett by conflating two separate powers—the power to promulgate a rule in the first place (which must be expressly given) and the scope of that power once given (which may be implied).

As the Texas Supreme Court explained, “When a statute expressly authorizes an agency to regulate an industry, it implies the authority to promulgate rules and regulations necessary to accomplish that purpose.” Id. The question in Pruett was not the existence of but the “scope of the Board’s rule-making authority.” Id. at 9.

The Attorney General also cites Public Utility Commission of Texas (PUC) v. City Pub. Serv. Bd. of S.A., 53 S.W.3d 310 (Tex. 2001). See Response at 9. Like Pruett, PUC is an express rulemaking authority case. The enabling statute in PUC states, “‘[t]he Commission shall adopt rules . . . relating to wholesale transmission services, rates, and access.’” 53 S.W.3d at 313 (emphasis added). The Texas Supreme Court in PUC explained that rulemaking authority must be expressly given: “As we have said before, the PUC is a creature of the legislature and has no inherent authority.

This is true of every state administrative agency and as a result every such agency has only those powers expressly conferred upon it by the Legislature.” Id. at 316 (internal quotations omitted). The court also explained that implied powers come into play only where there is first an express conferral of authority: “The basic rule is that a state administrative agency has only those powers that the legislature expressly confers upon it. But an agency may also have implied powers that are reasonably necessary to carry out the express responsibilities given to it by the legislature.” Id. at 315 (emphasis added).

In short, the Attorney General overstates the “concept of implied rulemaking authority.” Response at 10. Professor Beal—who has no stake in this litigation— refutes the Attorney General’s position more fully in his amicus brief. See R. Beal’s Amicus at 1-5.

**** The statutory history of Section 41.006 confirms that the Attorney General lacks the power to adopt the Challenged Rule—a point the Attorney General fundamentally misunderstands.

Originally, a separate provision gave the Attorney General the power to require reports, while the predecessor to Section 41.006 was merely a companion provision that obligated the district and county attorneys to cooperate. TEX. CODE OF CRIM. PRO. title. 1, ch. 2, sec. I, art. 30, (1879); id. title. 1, ch. 2, sec. II, art. 40.

The empowering provision only allowed the Attorney General to demand “information necessary for his compliance with” his own statutory obligation to make regular reports to the Governor. Id. title. 1, ch. 2, sec. I, art. 29, 30 (1879).

Then in the 1925 codification, the predecessor to Section 41.006 and the provision requiring reports to the Governor were moved, while the empowering provision was eliminated. TEX. REV. CIV STAT. title 70, ch. 4, art. 4413 (1925), id. title 15, sec. 3, art. 333.

This history underscores the absurdity of reading the Section 41.006 as a grant of rulemaking authority to the Attorney General. The Attorney General’s position in this case assumes that by repealing the empowering provision in a recodification, the legislature radically expanded the information that the Attorney General was permitted to demand. That is highly implausible. 2 B. The Challenged Rules exceed the Scope of Section 41.006.

Even assuming the Attorney General had the authority to adopt some rules under Section 41.006 (which he does not), it still would not authorize this rulemaking. “In deciding whether a particular administrative agency has exceeded

See H. Comm. on Judiciary, Bill Analysis at 4, Tex. S.B. 1228, 69th R.S. (1985) (emphasis added) (“It is the opinion of this committee that this bill does not delegate rulemaking authority to any state officer, agency, department, or institution.”). The Attorney General dismisses this key point as “irrelevant” because it involves “debate which took place on the [law’s] passage.” Response at 12. But there was no “debate” on rulemaking authority, just a clear statement from the Judiciary Committee that it was not conferred. its rule-making powers, the determinative factor is whether the rule’s provisions are ‘in harmony with the general objectives of the Act involved.’” Pruett v. Harris Cnty. Bail Bond Bd., 249 S.W.3d 447, 452 (Tex. 2008) (quoting Gerst v. Oak Cliff Sav. & Loan Ass'n, 432 S.W.2d 702, 706 (Tex. 1968)). There is a fundamental disconnect between a statute requiring ad hoc reports and an entirely new regulatory scheme with an oversight committee empowered to remove officials from office for any perceived violation thereof.

The Challenged Rules are also invalid because they “impose[] additional burdens, conditions, or restrictions in excess of . . . the relevant statutory provisions.” Tex. St. Bd. of Examiners of Marriage & Family Therapists v. Tex. Med.

Assoc., 511 S.W.3d 28, 33 (Tex. 2017). For example, Section 41.006 says nothing about penalties for noncompliance, including that noncompliance would constitute “official misconduct,” so the burden imposed by the threat of removal is plainly “in excess of” the statute. 1 TEX. ADMIN. CODE §§ 56.8. It is no answer to say that the Attorney General already has quo warranto power, because there can be no doubt that Section 56.8 redefines “official misconduct”—downgrading it from “intentional, unlawful behavior,” TEX. LOC. GOV’T CODE § 87.011, to a form of strict liability for any violation, “without limitation.” 1 TEX. ADMIN. CODE § 56.8 (1) & (2) (emphasis added). Other excesses exist too, such as the fact that Section 41.006 requires “reports” of “information,” not entire case files or internal correspondence.

C. The Challenged Rules violate the separation of powers.

On this point the Attorney General attempts to downplay his demands. But Appellees present a serious question that the Challenged Rules violate the Separation of Powers Clause by preventing the prosecuting attorneys from “effectively exercise[ing] [their] constitutionally assigned powers.” Martinez v. State, 323 S.W.3d 493, 501 (Tex. Crim. App. 2010) (emphasis in original). This is because the Challenged Rules’ reporting requirements compel compiling “all correspondence” and “entire case files” into collections that would otherwise not exist. 3 D. The regulations lack a reasoned justification.

The absence of any “reasoned justification” is apparent on inspection of the Texas Register entry adopting 1 TEX. ADMIN. CODE §§56.1-56.10. CR182. As demonstrated above, the Attorney General failed to give a reasoned justification for the compliance costs, the transfer of highly confidential information, or for deriving rulemaking authority from Section 41.006. And his claim that the population requirement “will indicate trends for all counties in the state,” CR186, can only be pretextual because there is no basis for assuming the largest counties

PRAYER Appellees pray that this Court grant its motion for temporary relief.

Respectfully submitted, [Signatures Beginning on Next Page]

/s/ Leslie W. Dippel /s/ Bradley W. Snead Leslie W. Dippel Jonathan G.C. Fombonne State Bar No. 00796472 Deputy County Attorney & First [email protected] Assistant Todd A. Clark State Bar No. 24102702 State Bar No. 04298850 [email protected] [email protected] Tiffany S. Bingham Cynthia W. Veidt Managing Counsel State Bar No. 24028092 Affirmative & Special Litigation Division [email protected] State Bar No. 24012287 Travis County Attorneys [email protected] DELIA GARZA Christopher Garza TRAVIS COUNTY ATTORNEY Deputy Division Director P.O. Box 1748 Affirmative & Special Litigation Division Austin, TX 78767 State Bar No. 24078543 Tel.: (512) 854-9513 [email protected] Fax: (512) 854-4808 Office of the Harris County Attorney CHRISTIAN D. MENEFEE Counsel for Appellees Delia Garza, in her HARRIS COUNTY ATTORNEY Official Capacity as Travis County Attorney, 1019 Congress Plaza, 15th Floor José P. Garza, in his Official Capacity as Houston, TX 77002 Travis County District Attorney, and Travis Tel.: (713) 274-5101 County Fax: (713) 755-8924 Bradley W. Snead /s/Justin C. Pfeiffer State Bar No. 24032706 Justin C. Pfeiffer [email protected] State Bar No. 24091473 Michael Adams-Hurta [email protected] State Bar No. 24097860 Gavrilov & Brooks, PC [email protected] P.O. Box 56632 WRIGHT CLOSE & BARGER, LLP Houston, TX 77256 One Riverway, Suite 2200 Tel.: (832) 312-7900 Houston, Texas 77056 Tel.: (713) 572-4321 Attorney for Appellee Brian M. Middleton, in Fax: (713) 572-4320 his Official Capacity as Fort Bend County District Attorney (268th Judicial District) Counsel for Appellees District Attorney Sean Teare and Harris County

/s/ Bernardo Cruz /s/Randy T. Leavitt Christina Sanchez C. Robert Heath El Paso County Attorney State Bar No. 09347500 State Bar No. 24062984 [email protected] [email protected] BICKERSTAFF HEATH DELGADO ACOSTA Bernardo Rafael Cruz 1601 S. Mopac Expy., Suite 400 Assistant County Attorney Austin, TX 78746 State Bar No. 24109774 Tel.: (512) 404-7821 [email protected] CHRISTNA SANCHEZ Randy T. Leavitt EL PASO COUNTY ATTORNEY State Bar No. 12098300 S. Campbell St., Suite 200 [email protected] El Paso, TX 79901 LAW OFFICE OF RANDY T. LEAVITT Tel.: (915) 273-3247 1301 Rio Grande St. Austin, TX 78701 Counsel for Appellees El Paso County District Tel.: (512) 476-4475 Attorney James Montoya, El Paso County Attorney Christina Sanchez, and El Paso County Attorneys for Appellee Shawn W. Dick in his Official Capacity as Williamson County District Attorney (26th Judicial District) /s/Michael Satin Alexandria Oberman State Bar No. 24131555 [email protected] Michael J. Statin (pro hac vice application forthcoming) [email protected] Laura G. Ferguson (pro hac vice application forthcoming) [email protected] MILLER & CHEVALIER CHARTERED 16th Street, NW Washington, DC 20006 Tel.: (202) 626-5800 Fax: (202) 626-5801 Counsel for Appellees Criminal District Attorney John Creuzot; Dallas County; Criminal District Attorney Joe Gonzales; and Bexar County Automated Certificate of eService This automated certificate of service was created by the efiling system.

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Alysa Slocum on behalf of Brad Snead Bar No. 24049835 [email protected] Envelope ID: 103056279 Filing Code Description: Other Document Filing Description: Appellees' Reply In Support of Appellees' Emergency Motion for Temporary Relief Status as of 7/14/2025 7:02 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Christopher Garza 24078543 [email protected] 7/11/2025 6:32:50 PM SENT Cynthia Veidt 24028092 [email protected] 7/11/2025 6:32:50 PM SENT Christina Sanchez 24062984 [email protected] 7/11/2025 6:32:50 PM SENT Jonathan Fombonne 24102702 [email protected] 7/11/2025 6:32:50 PM SENT William FCole [email protected] 7/11/2025 6:32:50 PM SENT Nicole A.Myette [email protected] 7/11/2025 6:32:50 PM SENT Tiffany Bingham 24012287 [email protected] 7/11/2025 6:32:50 PM SENT Nancy Villarreal [email protected] 7/11/2025 6:32:50 PM SENT William Farrell [email protected] 7/11/2025 6:32:50 PM SENT Joshua Woods [email protected] 7/11/2025 6:32:50 PM SENT Bradley W.Snead [email protected] 7/11/2025 6:32:50 PM SENT Michael Adams-Hurta [email protected] 7/11/2025 6:32:50 PM SENT Jacob Beach [email protected] 7/11/2025 6:32:50 PM SENT Ben Mendelson [email protected] 7/11/2025 6:32:50 PM SENT Cynthia W.Veidt [email protected] 7/11/2025 6:32:50 PM SENT William H. Farrell [email protected] 7/11/2025 6:32:50 PM SENT Leslie W. Dippel [email protected] 7/11/2025 6:32:50 PM SENT Todd A. Clark [email protected] 7/11/2025 6:32:50 PM SENT Cynthia W. Veidt [email protected] 7/11/2025 6:32:50 PM SENT Jonathan G.C. Fombonne [email protected] 7/11/2025 6:32:50 PM SENT Tiffany S. Bingham [email protected] 7/11/2025 6:32:50 PM SENT Christopher Garza [email protected] 7/11/2025 6:32:50 PM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system.

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Alysa Slocum on behalf of Brad Snead Bar No. 24049835 [email protected] Envelope ID: 103056279 Filing Code Description: Other Document Filing Description: Appellees' Reply In Support of Appellees' Emergency Motion for Temporary Relief Status as of 7/14/2025 7:02 AM CST Case Contacts Christopher Garza [email protected] 7/11/2025 6:32:50 PM SENT Justin C. Pfeiffer [email protected] 7/11/2025 6:32:50 PM SENT Christina Sanchez [email protected] 7/11/2025 6:32:50 PM SENT Bernardo Rafael Cruz [email protected] 7/11/2025 6:32:50 PM SENT C. RobertHeath [email protected] 7/11/2025 6:32:50 PM SENT Randy T. Leavitt [email protected] 7/11/2025 6:32:50 PM SENT Alexandria Oberman [email protected] 7/11/2025 6:32:50 PM SENT Michael J. Statin [email protected] 7/11/2025 6:32:50 PM SENT Laura G. Ferguson [email protected] 7/11/2025 6:32:50 PM SENT William H. Farrell H.Farrell [email protected] 7/11/2025 6:32:50 PM SENT Leslie W.Dippel [email protected] 7/11/2025 6:32:50 PM SENT Leslie W.Dippel [email protected] 7/11/2025 6:32:50 PM SENT Bradely W.Snead [email protected] 7/11/2025 6:32:50 PM SENT Bernardo Cruz [email protected] 7/11/2025 6:32:50 PM SENT Bernardo Cruz [email protected] 7/11/2025 6:32:50 PM SENT Bernardo Cruz [email protected] 7/11/2025 6:32:50 PM SENT Alexandria Oberman Oberman [email protected] 7/11/2025 6:32:50 PM SENT Alexandria Oberman [email protected] 7/11/2025 6:32:50 PM SENT Alexandria Oberman [email protected] 7/11/2025 6:32:50 PM SENT Melissa Contreras [email protected] 7/11/2025 6:32:50 PM SENT Isela Baeza [email protected] 7/11/2025 6:32:50 PM SENT Isela Jones [email protected] 7/11/2025 6:32:50 PM SENT Pamela Lopez [email protected] 7/11/2025 6:32:50 PM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system.

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Alysa Slocum on behalf of Brad Snead Bar No. 24049835 [email protected] Envelope ID: 103056279 Filing Code Description: Other Document Filing Description: Appellees' Reply In Support of Appellees' Emergency Motion for Temporary Relief Status as of 7/14/2025 7:02 AM CST Case Contacts Pamela Lopez [email protected] 7/11/2025 6:32:50 PM SENT Amy Pollock [email protected] 7/11/2025 6:32:50 PM SENT Michael J. Satin [email protected] 7/11/2025 6:32:50 PM SENT