State of Texas, Maxx Juusola, Tracy Martin, and Alan Crider v. City of Dallas, Kimberly Bizor Tolbert, in Her Official Capacity as the Interim City Manager for the City of Dallas and the State Fair of Texas

ACCEPTED 15-25-00122-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 9/22/2025 5:58 PM No. 15-25-00122-CV CHRISTOPHER A. PRINE CLERK IN THE COURT OF APPEALS FILED IN FOR THE FIFTEENTH JUDICIAL DISTRICT15th COURT OF APPEALS AUSTIN, TEXAS AUSTIN, TEXAS 9/22/2025 5:58:44 PM CHRISTOPHER A. PRINE Clerk STATE OF TEXAS, AND MAXX JUUSOLA, TRACY MARTIN, AND ALAN CRIDER, Appellants, v. CITY OF DALLAS, KIMBERLY BIZOR TOLBERT, IN HER OFFICIAL CAPACITY AS THE INTERIM CITY MANAGER FOR THE CITY OF DALLAS, AND THE STATE FAIR OF TEXAS, Appellees.

On Appeal from the 298th Judicial District Court, Dallas County ____________________________________________________ APPELLANT STATE OF TEXAS’S FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF ____________________________________________________ TO THE HONORABLE FIFTEENTH COURT OF APPEALS: Appellant, State of Texas (“State”) by and through Ken Paxton, Attorney General of Texas (Appellant), respectfully requests an extension of time to Friday, October 23, 2025, in which to file its brief in the captioned appeal. In support, the State would show the Court as follows: 1. Appellant’s brief is currently due on September 25, 2025. Appellant requests an extension of twenty-eight days. No previous extensions have been requested or granted.

2. Counsel for Appellant is in need of an extension due to emergent matters that arose in other cases which required a majority of his time before September 25, 2025.

3. This motion is not interposed for the purpose of delay, but only to allow counsel for the State to adequately prepare and file its brief.

4. Counsel for each Appellee has stated they do not oppose this request.

Appellant State of Texas therefore respectfully requests an extension of time to and including Friday, October 23, 2025, in which to file and serve its brief in the captioned appeal.

DATED: September 22, 2025.

Respectfully submitted, KEN PAXTON Attorney General of Texas BRENT WEBSTER First Assistant Attorney General RALPH MOLINA Deputy First Assistant Attorney General AUSTIN KINGHORN Deputy Attorney General for Civil Litigation ERNEST C. GARCIA Chief, Administrative Law Division /s/ Canon Parker Hill CANON PARKER HILL Assistant Attorney General State Bar No. 24140247 OFFICE OF THE ATTORNEY GENERAL OF TEXAS Administrative Law Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Telephone: (512) 936-1838 Facsimile: (512) 320-0167 [email protected] Counsel for Appellant, State of Texas

CERTIFICATE OF CONFERENCE I hereby certify that I contacted counsel Jeffery Tillotson for Appellee City of Dallas and Kimberly Tolbert in her official capacity as interim city manager, and counsel Jim Harris for Appellee State Fair of Texas, and that both counsels stated they are unopposed to the extension requested in this Motion.

/s/ Canon Parker Hill CANON PARKER HILL Assistant Attorney General

CERTIFICATE OF SERVICE I hereby certify that, in compliance with Rule 9.5 of the Texas Rules of Appellate Procedure, a true and correct copy of the above and foregoing document has been served on the following on this the 4th day of November 2021: Jeffrey Tillotson via e-service to: [email protected] Tillotson, Johnson & Patton 1201 Main Street, Suite 1300 Dallas, Texas 75202 Counsel for City of Dallas and Kimberly Tolbert Bryan Neal via e-service to: [email protected] Holland & Knight One Arts Plaza 1722 Routh Street, Suite 1500 Dallas, Texas 75201-2532 Counsel for State Fair of Texas Tony K. McDonald via e-service to: [email protected] State Bar No. 24083477 Connor Ellington via e-service to: [email protected] State Bar No. 24128592 The Law Offices of Tony McDonald 1308 Ranchers Legacy Trail Fort Worth, TX 76126 Counsel for Individual Plaintiffs /s/ Canon Parker Hill CANON PARKER HILL Assistant Attorney General

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.

Catherine Hughes on behalf of Canon Hill Bar No. 24140247 [email protected] Envelope ID: 105930940 Filing Code Description: Motion Filing Description: Motion for Extension Status as of 9/23/2025 7:13 AM CST Associated Case Party: City of Dallas Name BarNumber Email TimestampSubmitted Status Joseph AIrrobali [email protected] 9/22/2025 5:58:44 PM SENT Nathaniel Buchheit [email protected] 9/22/2025 5:58:44 PM SENT Megan Coker [email protected] 9/22/2025 5:58:44 PM SENT Anne Johnson [email protected] 9/22/2025 5:58:44 PM SENT Jeffrey Tillotson 20039200 [email protected] 9/22/2025 5:58:44 PM SENT

Associated Case Party: State Fair of Texas Name BarNumber Email TimestampSubmitted Status James Harris 9065400 [email protected] 9/22/2025 5:58:44 PM SENT Sherri Rodgers [email protected] 9/22/2025 5:58:44 PM SENT Bryan Neal 788106 [email protected] 9/22/2025 5:58:44 PM SENT Robert B.Smith [email protected] 9/22/2025 5:58:44 PM SENT

Associated Case Party: State of Texas Name BarNumber Email TimestampSubmitted Status Melissa Juarez [email protected] 9/22/2025 5:58:44 PM SENT Meridith Fischer [email protected] 9/22/2025 5:58:44 PM SENT Ernest Garcia [email protected] 9/22/2025 5:58:44 PM SENT Catherine Hughes [email protected] 9/22/2025 5:58:44 PM SENT Canon ParkerHill [email protected] 9/22/2025 5:58:44 PM SENT Steven Ogle [email protected] 9/22/2025 5:58:44 PM SENT 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.

Catherine Hughes on behalf of Canon Hill Bar No. 24140247 [email protected] Envelope ID: 105930940 Filing Code Description: Motion Filing Description: Motion for Extension Status as of 9/23/2025 7:13 AM CST Associated Case Party: State of Texas Steven Ogle [email protected] 9/22/2025 5:58:44 PM SENT Holly Dudrick [email protected] 9/22/2025 5:58:44 PM SENT

Case Contacts Name BarNumber Email TimestampSubmitted Status Kira Lytle [email protected] 9/22/2025 5:58:44 PM SENT TJP Service [email protected] 9/22/2025 5:58:44 PM SENT William Cole [email protected] 9/22/2025 5:58:44 PM SENT William Peterson [email protected] 9/22/2025 5:58:44 PM SENT Bryan Neal [email protected] 9/22/2025 5:58:44 PM SENT Tony McDonald [email protected] 9/22/2025 5:58:44 PM SENT Devlin Browne [email protected] 9/22/2025 5:58:44 PM SENT

Associated Case Party: AlanCrider Name BarNumber Email TimestampSubmitted Status Connor Ellington [email protected] 9/22/2025 5:58:44 PM SENT

Associated Case Party: MaxxJuusola Name BarNumber Email TimestampSubmitted Status Connor Ellington [email protected] 9/22/2025 5:58:44 PM SENT

Associated Case Party: TracyMartin 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.

Catherine Hughes on behalf of Canon Hill Bar No. 24140247 [email protected] Envelope ID: 105930940 Filing Code Description: Motion Filing Description: Motion for Extension Status as of 9/23/2025 7:13 AM CST Associated Case Party: TracyMartin Name BarNumber Email TimestampSubmitted Status Connor Ellington [email protected] 9/22/2025 5:58:44 PM SENT