Appraisal Review Board of the Harris County Appraisal District v. Texas Workforce Commission and Redona Hall

ACCEPTED 15-25-00041-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 10/15/2025 1:00 PM No. 15-25-00041-CV CHRISTOPHER A. PRINE ____________________________________________________ CLERK FILED IN In the 15th COURT OF APPEALS AUSTIN, TEXAS Fifteenth Court of Appeals 10/15/2025 1:00:42 PM Austin, Texas CHRISTOPHER A. PRINE Clerk ____________________________________________________ APPRAISAL REVIEW BOARD OF THE HARRIS COUNTY APPRAISAL DISTRICT, Appellant v. TEXAS WORKFORCE COMMISSION and REDONA HALL, Appellees ____________________________________________________ Appellee Texas Workforce Commission’s Second Unopposed Motion for Extension of Time to File Response Brief ____________________________________________________ Appellee, Texas Workforce Commission (“TWC”) files this second unopposed motion for extension of time to file its brief under Texas Rules of Appellate Procedure 10.5(b) and requests that the time for filing its response brief in this matter be extended for thirty (30) days, from November 3, 2025, to November 21, 2025, and in support shows as follows: 1. Respondent TWC’s Brief is due November 3, 2025.

2. Appellee TWC requests an additional 18 days to file its Brief, extending the deadline to November 21, 2025.

3. This is TWC’s second request for an extension of time to file its brief.

Appellee TWC’s Second Unopposed Motion for Extension of Time to File Brief P a g e |1 4. Good cause exists to grant this extension. TWC requests more time to review the arguments raised by Appellant and analyze the possible impact Appellant’s arguments would have on the regarding TWC’s interpretation of the relevant statutory schemes and TWC’s policies.

Similarly, counsel for TWC would request more time to thoroughly address all arguments raised by Appellant. TWC does not anticipate that any further requests for extension will be needed.

5. This extension is not being sought for purposes of delay but rather to allow time to prepare a thorough, succinct, and clear brief to be presented to the Court.

6. Counsel for TWC has conferred with counsel for Appellant, Ray Viada, and he is not opposed to this motion.

7. All facts in this motion are within the personal knowledge of the undersigned counsel, so no verification is necessary under Texas Rule of Appellate Procedure 10.2.

8. Wherefore, Appellee Texas Workforce Commission, requests that this motion be granted, and that the time for filing its Brief be extended to November 21, 2025.

Appellee TWC’s Second Unopposed Motion for Extension of Time to File Brief P a g e |2 Respectfully submitted, KEN PAXTON Attorney General BRENT WEBSTER First Assistant Attorney General RALPH MOLINA Deputy First Assistant Attorney General AUSTIN KINGHORN Deputy Attorney General for Civil Litigation STEVEN ROBINSON Chief, Tax Litigation Division /s/ William Cohen William Cohen Assistant Attorney General Texas Bar No. 24082839 [email protected] Tax Litigation Division Office of the Attorney General P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Tel: (512) 475-1743 Fax: (512) 478-4013 ATTORNEY FOR APPELLEE TEXAS WORKFORCE COMMISSION

Appellee TWC’s Second Unopposed Motion for Extension of Time to File Brief P a g e |3 CERTIFICATE OF CONFERENCE On October 15, 2025, the undersigned counsel conferred with Ray Viada, counsel for Appellant, via email. Mr. Viada does not oppose this Motion.

/s/ William Cohen WILLIAM COHEN Assistant Attorney General

CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing document was served on counsel by e-service and/or e-mail on October 15, 2025, as indicated below: Ray Viada [email protected] VIADA & STRAYER Counsel for Appellant

/s/ William Cohen WILLIAM COHEN Assistant Attorney General

Appellee TWC’s Second Unopposed Motion for Extension of Time to File Brief P a g e |4 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.

Lynee Pearson on behalf of William Cohen Bar No. 24082839 [email protected] Envelope ID: 106874940 Filing Code Description: Motion Filing Description: 20251015 Appellees Second Unopposed Motion for Extension Status as of 10/15/2025 1:16 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jennifer Holloway [email protected] 10/15/2025 1:00:42 PM SENT Ramon G.Viada [email protected] 10/15/2025 1:00:42 PM SENT Valerie Locher [email protected] 10/15/2025 1:00:42 PM SENT

Associated Case Party: Texas Workforce Commission Name BarNumber Email TimestampSubmitted Status William Cohen 24082839 [email protected] 10/15/2025 1:00:42 PM SENT