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 8/21/2025 4:09 PM No. 15-25-00022-CV CHRISTOPHER A. PRINE CLERK In the Court of Appeals FILED IN For the Fifteenth Judicial District of Texas 15th COURT OF APPEALS AUSTIN, TEXAS 8/21/2025 4:09:39 PM CHRISTOPHER A. PRINE CITY OF COPPELL, TEXAS, ET AL., Clerk Appellants/Cross-Appellees, v. KELLY HANCOCK, ACTING COMPTROLLER OF PUBLIC ACCOUNTS OF THE STATE OF TEXAS, Appellee/Cross-Appellant.

On Appeal from the 201st Judicial District Court, Travis County, Texas Cause No. D-1-GN-21-003198; consolidated with D-1-GN-21-003203 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 STEVEN ROBINSON Holland & Knight LLP Division Chief, Tax Litigation Division 1722 Routh Street, Suite 1500 KYLE PIERCE COUNCE Dallas, Texas 75201 State Bar No. 24082862 Phone: (214) 964-9500 [email protected] Assistant Attorney General Counsel for Coppell Tax Litigation Division Parties P. O. Box 12548 Austin, Texas 78711-2548 Phone: (512) 463-3112 Counsel for Comptroller

Page 1 of 7 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 Wednesday, August 27, 2025. The requested extension would make the briefs due on Friday, September 26, 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 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

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.

Page 2 of 7 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 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 initial appellate filing and the appellants’ opening brief on appeal, 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 reply in support of a motion to dismiss certain appellants filed on August 4, 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) preparing for and attending the hearing on plaintiffs’ motion for judgment on August 12, 2025, in Cause No. 2020-32320, Bestway Oilfield, Inc. v. Cox, et al., pending in the 270th Judicial District Court, Harris County, Texas; (e) assisting (on an emergency basis) with responding to a motion filed in No. CJ-2025-641, Capron v. Comerica Bank, pending in the District Court of Tulsa County, Oklahoma; (f) preparing and filing the relators’ reply in support of their petition for writ of mandamus on August 13, 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 (following 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; and

Page 3 of 7 (h) preparing the opening brief of appellant due on September 2, 2025, in No. 10-25-00088-CV, In re Estate of Kling (consolidated for briefing with No. 10-25-00089-CV, In re Guardianship of Kling), pending in the Court of Appeals for the Tenth District of Texas.

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: a) Deborah J. Rao, who had been lead counsel on this appeal prior to the Comptroller filing its change of designation of agency counsel on July 29, 2025, left the Office of the Attorney General and thus will not be available to assist with the appellate briefing; b) working on Discovery, 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) working on a Plea to the Jurisdiction and Motion for Summary Judgment in Cause No. D-1-GN-19-003740, The Consortium Venture, Inc., v. Glenn Hegar, Comptroller of Public Accounts of the State of Texas and Ken Paxton, Attorney General of the State of Texas, pending in the 53rd District Court of Travis County, Texas; d) assisting with a Joint Motion for Summary Judgment, set for August 12, 2025, in Cause No. 2023-CI-27126, Liza Zambrano v. Texas Workforce Commission and Lux Bakery, Inc., pending in the 288th District Court of Bexar County, Texas; e) assisting with a Plea to the Jurisdiction, set for August 10, 2025, in Cause No. 2020-CI-12466, Steve A. Casarez v. Texas Workforce Commission, pending in the 37th District Court of Bexar County, Texas;

Page 4 of 7 f) assisting with a Plea to the Jurisdiction, set for August 13, 2025, in Cause No. 2024-CI-24564, Glenn Samuels v. Texas Workforce Commission, pending in the 288th District Court of Bexar County, Texas; and g) 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; Therefore, the Coppell Parties and the Comptroller request that the Court extend the deadline for their opening briefs to Friday, September 26, 2025. The Coppell Parties and the Comptroller further request general relief.

Page 5 of 7 Dated: August 21, 2025 Respectfully submitted,

HOLLAND & KNIGHT LLP KEN PAXTON Attorney General of Texas By: /s/ James B. Harris (with permission) BRENT WEBSTER James B. Harris First Assistant Attorney General State Bar No. 09065400 [email protected] RALPH MOLINA Deputy First Assistant Attorney Stephen F. Fink General State Bar No. 07013500 [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 ATTORNEYS FOR COMPTROLLER

Page 6 of 7 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 Deputy Division Chief

Page 7 of 7 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.

Kyle Counce on behalf of Kyle Counce Bar No. 24082862 [email protected] Envelope ID: 104696116 Filing Code Description: Motion Filing Description: 20250821 Coppell Sales Joint Motion to Extend Deadline f Status as of 8/21/2025 5:00 PM CST Associated Case Party: City of Coppell, Texas Name BarNumber Email TimestampSubmitted Status Richard Phillips 24032833 [email protected] 8/21/2025 4:09:39 PM SENT Reed Randel 24075780 [email protected] 8/21/2025 4:09:39 PM SENT Stephen Fink 7013500 [email protected] 8/21/2025 4:09:39 PM SENT James Harris 9065400 [email protected] 8/21/2025 4:09:39 PM SENT

Case Contacts Name BarNumber Email TimestampSubmitted Status Bryan Dotson 24072769 [email protected] 8/21/2025 4:09:39 PM SENT Cynthia Bourland 790343 [email protected] 8/21/2025 4:09:39 PM SENT Brandon L.King [email protected] 8/21/2025 4:09:39 PM SENT

Associated Case Party: Glenn Hegar, in his official capacity as Texas Comptroller of Public Accounts Name BarNumber Email TimestampSubmitted Status Kyle Counce 24082862 [email protected] 8/21/2025 4:09:39 PM SENT