State of Texas v. City of San Antonio, Ron Niremberg, in His Official Capacity as Mayor of the City of San Antonio, and Erik Walsh, in His Official Capacity as City Manager of the City of San Antonio

ACCEPTED 15-25-00093-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 8/6/2025 9:24 AM No. 15-25-00093-CV CHRISTOPHER A. PRINE CLERK In the Court of Appeals for the Fifteenth Judicial District The State of Texas, Appellant, v. City of San Antonio; Ron Nirenberg, in his official capacity as Mayor of the City of San Antonio; Erik Walsh, in his official capacity as City Manager of the City of San Antonio, Appellees.

On Appeal from the 407th Judicial District Court, Bexar County UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S OPENING BRIEF In accordance with Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), Ap- pellant the State of Texas files this motion for extension of time to file Appellant’s opening brief. Appellant’s opening brief is currently due on August 20, 2025. Appel- lant requests a 30-day extension of this deadline, up to and including September 19, 2025. This is Appellant’s first request for an extension for this filing and it is unop- posed.

I.

The requested 30-day extension is necessary due to Appellant’s counsel’s mul- tiple engagements that have required and will require significant attention. Some ex- amples include: • Assisting in emergency proceedings in Institutional Shareholder Services, Inc. v. Paxton, 1:25-cv-01160 (W.D. Tex.); • Assisting in emergency proceedings in Sophia Myers et al. v. Stephen F. Austin State University, 9:25-cv-00187 (E.D. Tex.); and • Mandamus and stay proceedings in In re Texas Department of Family and Protec- tive Services, 25-0663 (Tex.).

An extension of time will allow Appellant’s counsel to prepare a thorough open- ing brief that will be helpful to the Court in assessing the case’s merits. This unop- posed extension is sought in the interest of justice, not for delay, and no party will be prejudiced if this extension is granted.

II.

For these reasons, Appellant requests that the Court grant its unopposed motion for a 30-day extension of time to file its opening brief, resulting in a new deadline of September 19, 2025.

Respectfully submitted.

Ken Paxton William R. Peterson Attorney General of Texas Solicitor General Brent Webster /s/ Nathaniel A. Plemons First Assistant Attorney General Nathaniel A. Plemons Assistant Solicitor General Office of the Attorney General State Bar No. 24121059 P.O. Box 12548 (MC 059) [email protected] Austin, Texas 78711-2548 Tel.: (512) 936-1700 Fax: (512) 474-2697 Counsel for Appellant

Certificate of Conference I certify that on August 5, 2025, I conferred with Kennon Wooten, counsel for Appellees, by email, who informed me that Appellees do not oppose the extension sought through this motion.

/s/ Nathaniel A. Plemons Nathaniel A. Plemons

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.

Nancy Villarreal on behalf of Nathaniel Plemons Bar No. 24121059 [email protected] Envelope ID: 104026491 Filing Code Description: Motion Filing Description: 20250805 SA Abortion Travel MET Opening Br_FINAL Status as of 8/6/2025 9:33 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Kennon Wooten 24046624 [email protected] 8/6/2025 9:24:42 AM SENT Deborah Klein 11556750 [email protected] 8/6/2025 9:24:42 AM SENT Maria Williamson [email protected] 8/6/2025 9:24:42 AM SENT Lauren Ditty 24116290 [email protected] 8/6/2025 9:24:42 AM SENT Abril Rivera [email protected] 8/6/2025 9:24:42 AM SENT Jordan Kadjar [email protected] 8/6/2025 9:24:42 AM SENT Carla Matheson [email protected] 8/6/2025 9:24:42 AM SENT Nancy Villarreal [email protected] 8/6/2025 9:24:42 AM SENT

Associated Case Party: The State of Texas Name BarNumber Email TimestampSubmitted Status Amy Hilton 24097834 [email protected] 8/6/2025 9:24:42 AM SENT Katherine Pitcher 24143894 [email protected] 8/6/2025 9:24:42 AM SENT Nathaniel Plemons [email protected] 8/6/2025 9:24:42 AM SENT