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 7/18/2025 4:33 PM NO. 15-25-00018-CV CHRISTOPHER A. PRINE CLERK IN THE COURT OF APPEALS FILED IN FOR THE FIFTEENTH JUDICIAL DISTRICT 15th COURT OF APPEALS AUSTIN, TEXAS AT AUSTIN, TEXAS 7/18/2025 4:33:47 PM CHRISTOPHER A. PRINE PUBLIC UTILITY COMMISSION OF TEXAS, Clerk 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 their reply briefs in support of their respective appeals before this Court.

1. Appellant/Cross-Appellant’s Reply Briefs are currently due on August 4, 2025.

2. The PUC and DME seek a 20-day extension of time to file their reply briefs, which would make the briefs due on or before Monday, August 25, 2025.

3. This extension of time is necessary because of upcoming scheduling conflicts that would impact the briefing schedule in this matter.

4. Counsel for DME has three other appellate briefs due on Monday, August 4, 2025. Counsel for Cross-Appellant has two reply briefs due to the Thirteenth Court of Appeals in Aranas County v. Western Steel Company and T2J Partners LLC, No. 13-25-00148-CV. The same day, counsel for Cross-Appellant has an initial brief due in the appeal styled Aransas County, Texas v. T2J Partners, LLC, No. 13-25- 00323-CV in the Thirteenth Court.

5. On July 28, 2025, counsel for Cross-Appellant has a reply brief due to this Court in the appeal styled Nicholas Kreines, et al. v. ES3 Minerals, LLC., No. 15-25-00027-CV. Counsel for Appellants has another appellate brief also due on July 28, 2025, to the Thirteenth Court of Appeals in Aransas County v. NorthStar Recovery Services, Inc., No. 13-25-00159-CV.

6. In addition to the pending appellate deadlines, counsel for Appellant has a series of 17 depositions that are scheduled to occur over four weeks beginning on July 31 in ES3 Minerals, LLC v. Nicholas

Kreines, et al., Cause No. 24-BC03B-0005 (Third Division of the Texas Business Court).

7. Finally, lead counsel for DME will be out of the office July 25 through August 3, 2025.

8. Counsel for the PUC has to prepare for a hearing on the merits on July 29, 2025, in two related cases styled TCCI Range-Mead 2021, LLC, v. Public Utility Commission of Texas, Cause No. D-1-GN- 008563 (459th Judicial District, Travis County, Texas) and TCCI Ponder Farms 2021 LLC, v. Public Utility Commission of Texas, Cause No. D-1- GN-24-010011 (250th Judicial District, Travis County, Texas).

9. Additionally, counsel for the PUC has an appellate brief due to this Court on August 15, 2025, in the appeal styled City of College Station v. Public Utility Commission of Texas, No. 15-25-00096-CV.

Should the Court grant this Joint Motion, Appellant’s and Cross- Appellant’s briefs in support of their respective appeals would be due on or before August 25, 2025.

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 their Joint Motion for Extension of Time and that their respective reply briefs, will be due on or before August 25, 2025.

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. 10258400 State Bar No. 24093172 [email protected] [email protected] JORDAN PRATT JAMIE L. MAULDIN State Bar No. 24140277 State Bar No. 24065694 [email protected] [email protected] ROSLYN M. WARNER ATTORNEYS FOR APPELLANT / State Bar No. 24117520 CROSS-APPELLEE [email protected] 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: 103336329 Filing Code Description: Motion Filing Description: Joint Motion for Extension of Time to File Reply Briefs Status as of 7/18/2025 4:49 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Katherine Coleman 24059596 [email protected] 7/18/2025 4:33:47 PM SENT Jamie Mauldin 24065694 [email protected] 7/18/2025 4:33:47 PM SENT Gabrielle Smith 24093172 [email protected] 7/18/2025 4:33:47 PM SENT David Laurent [email protected] 7/18/2025 4:33:47 PM SENT John RHulme [email protected] 7/18/2025 4:33:47 PM SENT Jose E.de la Fuente [email protected] 7/18/2025 4:33:47 PM SENT Amy Hoffee [email protected] 7/18/2025 4:33:47 PM SENT Chris Ekoh [email protected] 7/18/2025 4:33:47 PM SENT Justin Swearingen [email protected] 7/18/2025 4:33:47 PM SENT Jordan Pratt [email protected] 7/18/2025 4:33:47 PM SENT Colton Halter [email protected] 7/18/2025 4:33:47 PM SENT John Hubbard [email protected] 7/18/2025 4:33:47 PM SENT Christiana Segura 24143396 [email protected] 7/18/2025 4:33:47 PM SENT James ScottMcCarley [email protected] 7/18/2025 4:33:47 PM SENT Devin Alexander [email protected] 7/18/2025 4:33:47 PM SENT Roslyn Warner [email protected] 7/18/2025 4:33:47 PM SENT Michael McMillin [email protected] 7/18/2025 4:33:47 PM SENT Sharbel Sfeir [email protected] 7/18/2025 4:33:47 PM SENT Marcella Lunn [email protected] 7/18/2025 4:33:47 PM SENT Michael Martinez [email protected] 7/18/2025 4:33:47 PM SENT