Texas Court of Appeals, 15th District, 2025

Hays County, Texas, Ruben Becerra, Debbie Ingalsbe, Michelle Cohen, Morgan Hammer, and Walt Smith, in Their Official Capacities v. Leslie Carnes, Jim Camp, Cathy Ramsey, Gabrielle Moore, and Ken Paxton, Attorney General of Texas

Hays County, Texas, Ruben Becerra, Debbie Ingalsbe, Michelle Cohen, Morgan Hammer, and Walt Smith, in Their Official Capacities v. Leslie Carnes, Jim Camp, Cathy Ramsey, Gabrielle Moore, and Ken Paxton, Attorney General of Texas
Texas Court of Appeals, 15th District · Decided November 18, 2025
Hays County, Texas, Ruben Becerra, Debbie Ingalsbe, Michelle Cohen, Morgan Hammer, and Walt Smith, in Their Official Capacities v. Leslie Carnes, Jim Camp, Cathy Ramsey, Gabrielle Moore, and Ken Paxton, Attorney General of Texas

Opinion

ACCEPTED 15-25-00121-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 11/18/2025 5:59 PM CHRISTOPHER A. PRINE CLERK THE OFFICE OF THE ATTORNEY GENERAL OF TEXAS FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS November 18, 2025 11/18/2025 5:59:56 PM CHRISTOPHER A. PRINE Clerk Christopher A. Prine Via EFileTexas.gov Clerk of the Court William P. Clements Building W. 15th Street, Suite 607 Austin, Texas 78701 RE: Court of Appeals Number: 15-25-00121-CV Trial Court Case Number: D-1-GN-25-002049 Style: Hays County, Texas, Ruben Becerra, Debbie Ingalsbe, Michelle Cohen, Morgan Hammer, and Walt Smith, in their official capacities v. Leslie Carnes, Jim Camp, Cathy Ramsey, Gabrielle Moore, and Ken Paxton, Attorney General of Texas Dear Mr. Pine: Ken Paxton, Attorney General of Texas, files this waiver of Response to the Appellants’ brief on the merits, which was filed on October 10th, 2025.

This appeal arises from a bond validation proceeding under the Expedited Declaratory Judgment Act (“EDJA”), Chapter 1205 of the Texas Government Code, filed in 2020. The Attorney General is a required party in such matters and has specific duties, including a duty to raise appropriate defenses, and a duty to help facilitate a just and expeditious resolution. See TEX. GOV’T CODE § 1205.063 (Duties of Attorney General).

Appellants state in their appellate brief that the Attorney General took no position on the Texas Open Meetings Act issue in the trial court. That is correct. However, if the notice of the meeting calling a bond election is not valid, then the bonds are not valid. In this regard, in his trial brief the Attorney General set forth issues the trial court should consider in determining whether the County complied with the Texas Open Meetings Act.

Because the remaining issue with Appellants, the SH-45 project, has been resolved, the Attorney General, respectfully, will not be filing an appellate brief.

Respectfully submitted,

Post Office Box 12548, Austin, Texas 78711-2548 • (512) 463-2100 • www.texasattorneygeneral.gov Clerk of the Court Fifteenth Court of Appeals 15-25-00121-CV; Hays County, Texas, et al. v. Leslie Carnes, et al.

Page 2 __________________________________

/s/ Lynn E. Saarinen LYNN E. SAARINEN Assistant Attorney General Texas Bar No. 1748900 General Litigation Division P.O. Box 12548 MC 019-1 Austin, Texas 78711-2548 Tel: (737) 224-4634 |Fax: (512) 477-2348 [email protected] Counsel for Appellee, Ken Paxton, Attorney General of Texas

CERTIFICATE OF SERVICE I certify that on November 18, 2025, the foregoing was filed and served on all parties of record via EFileTexas.gov.

/s/ Lynn E. Saarinen LYNN E. SAARINEN 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.

Tristan Garza on behalf of Lynn Saarinen Bar No. 17498900 [email protected] Envelope ID: 108204252 Filing Code Description: Response Filing Description: Waiver Status as of 11/19/2025 8:11 AM CST Associated Case Party: HAYS COUNTY Name BarNumber Email TimestampSubmitted Status Ian M.Davis [email protected] 11/18/2025 5:59:56 PM SENT

Case Contacts Name BarNumber Email TimestampSubmitted Status Raymond Abarca [email protected] 11/18/2025 5:59:56 PM SENT Michael Shaunessy [email protected] 11/18/2025 5:59:56 PM SENT Julie Denny [email protected] 11/18/2025 5:59:56 PM SENT Amy Botelho [email protected] 11/18/2025 5:59:56 PM SENT Austin Jones [email protected] 11/18/2025 5:59:56 PM SENT Bill Aleshire [email protected] 11/18/2025 5:59:56 PM SENT Bill Bunch [email protected] 11/18/2025 5:59:56 PM SENT Bobby Levinski [email protected] 11/18/2025 5:59:56 PM SENT William Gammon [email protected] 11/18/2025 5:59:56 PM SENT Lynn Saarinen [email protected] 11/18/2025 5:59:56 PM SENT Rosemarie Kanusky [email protected] 11/18/2025 5:59:56 PM SENT Matthew PhilipHines [email protected] 11/18/2025 5:59:56 PM SENT

Case-law data current through December 31, 2025. Source: CourtListener bulk data.