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 10/17/2025 3:38 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., 10/17/2025 3:38:13 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 All Parties’ Joint Motion to Extend Time to File Response Briefs James B. Harris Cindy Olson Bourland State Bar No. 09065400 State Bar No. 00790343 [email protected] [email protected] Stephen F. Fink Bourland Law Firm, P.C.

State Bar No. 07013500 P.O. Box 546 [email protected] Round Rock, Texas 78680 Richard B. Phillips, Jr. State Bar No. 24032833 Bryan J. Dotson [email protected] State Bar No. 24072769 Reed C. Randel [email protected] State Bar No. 24075780 Chamberlain, Hrdicka, White, [email protected] Williams & Aughtry, P.C.

Holland & Knight LLP 112 East Pecan Street, Ste. 1450 1722 Routh Street, Suite 1500 San Antonio, Texas 78205 Dallas, Texas 75201 Phone: (214) 964-9500 Counsel for Appellee City of Round Rock, Texas Counsel for Cross- Appellees the Coppell Parties 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 STEVEN ROBINSON Division Chief, Tax Litigation Division KYLE PIERCE COUNCE State Bar No. 24082862 [email protected] Assistant Attorney General Tax Litigation Division P. O. Box 12548 Austin, Texas 78711-2548 Phone: (512) 463-3112 Counsel for Appellee Kelly Hancock, in His Official Capacity as Acting Comptroller of Public Accounts of the State of Texas

Joint Motion to Extend Time to File Response Briefs— Page 2 To the Honorable Court of Appeals: 1. Under Texas Rules of Appellate Procedure 2, 10.5(b), and 38.6(d), Appellee City of Round Rock, Texas (“Round Rock”), Appellee Kelly Hancock, in His Official Capacity as Acting Comptroller of Public Accounts of the State of Texas (“Comptroller”), and Cross-Appellees City Coppell, Texas, City of Humble, Texas, City of DeSoto, Texas, City of Carrollton, Texas, and City of Farmers Branch, Texas (the “Coppell Parties”) respectfully request a 30-day extension on the due dates for their response 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. Round Rock’s response brief as appellee, the Comptroller’s response brief as appellee, and the Coppell Parties’ response brief as cross-appellees are all currently due on Monday, October 27, 2025. The requested extensions would make the briefs due on Wednesday, November 26, 2025. This is the first request for extension of the due dates for these briefs.

3. No party opposes any other party’s request for an extension of time.

4. Round Rock requests this extension because its counsel has been and will be occupied with other case matters and travel that will prevent them from filing the brief by the current due date. Among other matters, lead counsel Cindy Olson

Joint Motion to Extend Time to File Response Briefs—Page 1 Bourland will be out of state from October 24 to October 31, 2025, and also needs additional time to thoroughly research and address the issues presented by this appeal.

5. The Comptroller requests this extension because their lead counsel, Kyle Pierce Counce, is occupied with other case matters that will prevent them from filing the brief by the current due date. Among other matters, lead counsel has been occupied with the following: (a) preparing for and presenting oral argument on October 30, 2025, in No. 15- 24-00113-CV, Hancock v. American Airlines, Inc., pending in this Court; (b) assisting in preparation for oral argument on October 30, 2025 (oral argument canceled on October 16, 2025), in No. 15-24-00111-CV, Hancock v. Championx, LLC; (c) preparing for a Plea to the Jurisdiction hearing held on October 15, 2025 in No. D-1-GN-25-000438, City of Lancaster v. Hegar, et al., pending in the 345th Judicial District Court of Travis County, Texas; and (d) mediating Cause No. 3:23-cv-00810, Stinson v. Jones, et al., in the United States District Court for the Northern District of Texas.

6. The Coppell Parties request this extension primarily because their lead counsel, James B. Harris, will be out of the country on a long-planned 50th wedding anniversary trip to Africa from October 9 through October 27. The trip covers most of the time to prepare the response brief and Mr. Harris will still be out of the country on the current due date. Additionally, the Coppell Parties other counsel has been

Joint Motion to Extend Time to File Response Briefs—Page 2 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) preparing the appellee’s response brief due on October 8, 2025, in Miller v. Dunn, et al., No. 05-25-00768-CV, pending in the Court of Appeals for the Fifth District of Texas; (b) preparing the appellants’ opening brief in Cockerill, et al. v. Corteva, et al.., No. 25-2204 and No. 25-2312, pending in the United States Court of Appeals for the Third Circuit; (c) preparing the petition for review due on October 29, 2025, in 25-0863, Southern Cornerstone, Inc. v. Crown Colony Improvement Association, Inc., pending the Supreme Court of Texas; and (d) preparing for and presenting oral argument on October 30, 2025, in No. 15- 24-00113-CV, Hancock v. American Airlines, Inc., pending in this Court.

Therefore, Round Rock, the Comptroller, and the Coppell Parties request that the Court extend the deadline for their response briefs to Wednesday, November 26, 2025.

Joint Motion to Extend Time to File Response Briefs—Page 3 Dated: October 17, 2025 Respectfully submitted, Holland & Knight LLP Bourland Law Firm, P.C.

P.O. Box 546 By: /s/ Richard B. Phillips, Jr. Round Rock, Texas 78680 James B. Harris State Bar No. 09065400 By: /s/ Cindy Olson Bourland [email protected] Cindy Olson Bourland Stephen F. Fink State Bar No. 00790343 State Bar No. 07013500 [email protected] [email protected] Richard B. Phillips, Jr. Chamberlain, Hrdicka, State Bar No. 24032833 White, Williams & [email protected] Aughtry, P.C.

Reed C. Randel Bryan J. Dotson State Bar No. 24075780 State Bar No. 24072769 [email protected] [email protected] 1722 Routh Street, Suite 1500 112 East Pecan Street, Ste. 1450 Dallas, Texas 75201 San Antonio, Texas 78205 Phone: (214) 964-9500 Counsel for The City of Counsel for The Coppell Round Rock, Texas Parties

Joint Motion to Extend Time to File Response Briefs—Page 4 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 STEVEN ROBINSON Division Chief, Tax Litigation Division /s/ Kyle Pierce Counce KYLE PIERCE COUNCE State Bar No. 24082862 [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 Kelly Hancock, in His Official Capacity as Acting Comptroller of Public Accounts of the State of Texas

Joint Motion to Extend Time to File Response Briefs—Page 5 Certificate of Conference This is a joint request by all parties to this appeal and all parties have consented to the extensions requested by the other parties.

/s/ Richard B. Phillips, Jr. Richard B. Phillips, Jr.

Joint Motion to Extend Time to File Response 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: 106998333 Filing Code Description: Motion Filing Description: Joint Motion for Extension of Time to File Response Briefs Status as of 10/17/2025 3:44 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Richard Phillips 24032833 [email protected] 10/17/2025 3:38:13 PM SENT Bryan Dotson 24072769 [email protected] 10/17/2025 3:38:13 PM SENT Ray Langenberg 11911200 [email protected] 10/17/2025 3:38:13 PM SENT Reed Randel 24075780 [email protected] 10/17/2025 3:38:13 PM SENT Stephen Fink 7013500 [email protected] 10/17/2025 3:38:13 PM SENT James Harris 9065400 [email protected] 10/17/2025 3:38:13 PM SENT Kyle Counce 24082862 [email protected] 10/17/2025 3:38:13 PM SENT Cynthia Bourland 790343 [email protected] 10/17/2025 3:38:13 PM SENT Brandon L.King [email protected] 10/17/2025 3:38:13 PM SENT