City of Coppell, Texas; City of Humble, Texas; City of DeSoto, Texas; City of Carrollton, Texas; And City of Farmer's Branch, Texas // Kelly Hancock, in His Official Capacity as Acting Comptroller of Public Accounts of the State of Texas v. Kelly Hancock, in His Official Capacity as Acting Comptroller of Public Accounts of the State of Texas // City of Coppell, Texas; City of Humble, Texas; City of DeSoto, Texas; City of Carrollton, Texas; City of Farmer's Branch, Texas; And City of Round Rock, Texas

ACCEPTED 15-25-00022-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 7/23/2025 12:44 PM Cause No. 15-25-00022-CV CHRISTOPHER A. PRINE CLERK In the Court of Appeals FILED IN For the Fifteenth District of Texas 15th COURT OF APPEALS AUSTIN, TEXAS City of Coppell, Texas, et al., 7/23/2025 12:44:28 PM Appellants/Cross-Appellees, CHRISTOPHER A. PRINE Clerk v. Kelly Hancock, in His Official Capacity as Acting Comptroller of Public Accounts of the State of Texas, Appellee/Cross-Appellant.

Appeal from the 201st Judicial District Court of Travis County, Texas Hon. Karin Crump, Presiding Appellants’ and Cross-Appellant’s Joint Motion to Extend Time to File Opening Briefs James B. Harris KEN PAXTON State Bar No. 09065400 Attorney General of Texas [email protected] BRENT WEBSTER Stephen F. Fink First Assistant Attorney General State Bar No. 07013500 RALPH MOLINA [email protected] Deputy First Assistant Attorney General Richard B. Phillips, Jr. AUSTIN KINGHORN State Bar No. 24032833 Deputy Attorney General for Civil [email protected] Litigation Holland & Knight LLP STEVEN ROBINSON 1722 Routh Street, Suite 1500 Division Chief, Tax Litigation Division Dallas, Texas 75201 KYLE PIERCE COUNCE Phone: (214) 964-9500 State Bar No. 24082862 [email protected] Counsel for Coppell Assistant Attorney General Parties Tax Litigation Division P. O. Box 12548 Austin, Texas 78711-2548 Phone: (512) 463-3112 COUNSEL FOR COMPTROLLER To the Honorable Court of Appeals: 1. Under Texas Rules of Appellate Procedure 2, 10.5(b), and 38.6(d), Appellants City Coppell, Texas, City of Humble, Texas, City of DeSoto, Texas, City of Carrollton, Texas, and City of Farmers Branch, Texas (the “Coppell Parties”) and Cross-Appellant Kelly Hancock, in his official capacity as Acting Comptroller of Public Accounts of the State of Texas (the “Comptroller”) respectfully request a 30-day extension on the due dates for their opening briefs.

2. This is an appeal and cross-appeal arising from a dispute about the meaning of certain provisions of the Texas Tax Code and related rules in the Texas Administrative Code. The Coppell Parties’ opening brief as appellants and Comptroller’s opening brief as cross-appellant are currently due on Monday, July 28, 2025. The requested extension would make the briefs due on Wednesday, August 27, 2025.

3. The Comptroller is not opposed to the requested extension of the due date for the Coppell Parties’ opening brief. The Coppell Parties are not opposed to the requested extension of the due date for the Comptroller’s opening brief. And counsel

Joint Motion to Extend Time to File Opening Briefs—Page 1 for Appellee the City of Round Rock, Texas has indicated that the City of Round Rock is not opposed to the Comptroller’s requested extension.1 4. The Coppell Parties request this extension because their counsel has been and will be occupied with other matters that will prevent them from filing the brief by the current due date. Among other matters, counsel has been occupied with the following: (a) assisting with post-judgment briefing (including a motion to amend the judgment and a motion to stay enforcement of the judgment pending appeal) in Cockerill et al. v. Corteva, Inc., et al., No. 2:21-cv-03966-MMB, a class action pending in the United States District Court for the Eastern District of Pennsylvania; (b) assisting with a motion for a stay pending appeal filed on July 15, 2025, in No. 25-2312, Cockerill et al. v. Corteva, Inc., et al., pending in the United States Court of Appeals for the Third Circuit (the appeal arising from the class action described in item (a)); (c) preparing and filing a motion for temporary relief filed on July 10, 2025, in No. 15-24-00114-CV, Cecile E. Young, in her official capacity as Executive Commissioner of the Texas Health & Human Services Commission v. Cook Children’s Health Plan, et al., pending in the Court of Appeals for the Fifteenth District of Texas; (d) assisting with a motion to dismiss filed on July 11, 2025, in No. 15-24-00114- CV, Cecile E. Young, in her official capacity as Executive Commissioner of the Texas Health & Human Services Commission v. Cook Children’s Health Plan, et al., pending in the Court of Appeals for the Fifteenth District of Texas;

The City of Round Rock did not appeal the final judgment and therefore its only capacity in this Court is as an appellee as to the Comptroller’s cross-appeal.

Joint Motion to Extend Time to File Opening Briefs—Page 2 (e) preparing and filing the relator’s reply brief on the merits and supplemental mandamus record on July 11, 2025, in No. 24-0809, In re Regalia at the Park Holdings, LLC, pending in the Supreme Court of Texas; (f) preparing and filing the relators’ petition for writ of mandamus on July 9, 2025, in No. 13-25-00345-CV, In re QFP II, LP and RGV II, LLC, pending in the Court of Appeals for the Thirteenth District of Texas; (g) working on a petition for review due (after the grant of an extension) on August 13, 2025, in In re Estate of Long, No. 25-0601, pending in the Supreme Court of Texas; (h) preparing and filing the opening brief of the appellant due (after the grant of an extension) on August 18, 2025, in No. 10-25-00088-CV, In re Estate of Christopher Kling, Deceased and No. 10-25-00089-CV, In re Guardianship of Christopher Kling, an Incapacitated Person, pending in the Court of Appeals for the Tenth District of Texas; (i) providing advice to the City of University Park on how to respond to a threat to bring a suit for injunctive relief against the city on July 15, 2025; (j) providing advice to the Dallas Symphony Association by July 18, 2025, regarding the likelihood of success in litigation in response to actions proposed to be taken by the end of July; and (k) preparing and submitting position statements in connection with a hearing before the Dallas Appraisal Review Board on July 9, 2025, to consider an appeal of the property tax values on seven properties with a collective proposed appraised value of more than $60 million.

5. The Comptroller requests this extension because their counsel has been and will be occupied with other matters that will prevent them from filing the brief by the current due date. Among other matters, counsel has been occupied with the following:

Joint Motion to Extend Time to File Opening Briefs—Page 3 (a) Deborah J. Rao, who has been lead counsel on this appeal, will be leaving the Office of the Attorney General and will not be available to assist with the appellate briefing;2 (b) working on a Plea to the Jurisdiction and Motion for Summary Judgment in Cause No. D-1-GN-23-002189, Ryan, LLC, v. Kelly Hancock, in his Official Capacity as Acting Texas Comptroller of Public Accounts, pending in the 459th District Court of Travis County, Texas; (c) assisting with oral argument, set for September 10, 2025, in Cause No. 24- 0037, NuStar Energy, L.P., v. Kelly Hancock, Acting Texas Comptroller of Public Accounts and Ken Paxton, Attorney General of the State of Texas, pending the Supreme Court of Texas; and (d) preparing responsive pleadings in Cause No. 3:23-cv-00810-M, Crystal Stinson, DDS, PHD, v. Dr. Daniel Jones, et al., pending in the United States District Court for the Northern District of Texas.

Therefore, the Coppell Parties and the Comptroller request that the Court extend the deadline for their opening briefs to Wednesday, August 27, 2025. The Coppell Parties and the Comptroller further request general relief.

Dated: July 23, 2025

2 A notice of change of designation of agency counsel is forthcoming.

Joint Motion to Extend Time to File Opening Briefs—Page 4 Respectfully submitted, Holland & Knight LLP KEN PAXTON Attorney General of Texas By: /s/ Richard B. Phillips, Jr. BRENT WEBSTER James B. Harris First Assistant Attorney General State Bar No. 09065400 [email protected] RALPH MOLINA Stephen F. Fink Deputy First Assistant Attorney State Bar No. 07013500 General [email protected] AUSTIN KINGHORN Richard B. Phillips, Jr. Deputy Attorney General for Civil State Bar No. 24032833 Litigation [email protected] STEVEN ROBINSON 1722 Routh Street, Suite 1500 Division Chief, Tax Litigation Division Dallas, Texas 75201 Phone: (214) 964-9500 /s/ Kyle Pierce Counce KYLE PIERCE COUNCE Counsel for Coppell State Bar No. 24082862 Parties [email protected] Assistant Attorney General Tax Litigation Division P. O. Box 12548 Austin, Texas 78711-2548 T: (512) 463-3112 F: (512) 478-4013 COUNSEL FOR COMPTROLLER

Joint Motion to Extend Time to File Opening Briefs—Page 5 Certificate of Conference Counsel for the Comptroller discussed this motion with Cindy Olson Bourland, counsel for Appellee the City of Round Rock, Texas by email, who indicated that the City of Round Rock, Texas is not opposed to the requested extension.

/s/ Kyle Pierce Counce Kyle Pierce Counce

Joint Motion to Extend Time to File Opening Briefs—Page 6 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.

Richard Phillips on behalf of Richard Phillips Jr. Bar No. 24032833 [email protected] Envelope ID: 103488647 Filing Code Description: Motion Filing Description: Appellants' and Cross-Appellant's Joint Motion to Extend Time to File Opening Briefs Status as of 7/23/2025 1:28 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Richard Phillips 24032833 [email protected] 7/23/2025 12:44:28 PM SENT Bryan Dotson 24072769 [email protected] 7/23/2025 12:44:28 PM SENT Ray Langenberg 11911200 [email protected] 7/23/2025 12:44:28 PM SENT Reed Randel 24075780 [email protected] 7/23/2025 12:44:28 PM SENT Stephen Fink 7013500 [email protected] 7/23/2025 12:44:28 PM SENT James Harris 9065400 [email protected] 7/23/2025 12:44:28 PM SENT Kyle Counce 24082862 [email protected] 7/23/2025 12:44:28 PM SENT Cynthia Bourland 790343 [email protected] 7/23/2025 12:44:28 PM SENT Deborah Rao 24131915 [email protected] 7/23/2025 12:44:28 PM SENT Brandon L.King [email protected] 7/23/2025 12:44:28 PM SENT Kyle PierceCounce [email protected] 7/23/2025 12:44:28 PM SENT