ACCEPTED 15-25-00214-cv FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 12/12/2025 10:59 AM No. 15-25-00214-CV CHRISTOPHER A. PRINE CLERK In the Fifteenth Court of Appeals FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS TEXAS COMMISSION ON ENVIRONMENTAL QUALITY, 12/12/2025 10:59:15 AM Appellant, CHRISTOPHER A. PRINE vs. Clerk HARRIS COUNTY, TEXAS, et al., Appellees. ___________________________________________________ APPELLANT’S FIRST UNOPPOSED MOTION FOR EXTENSION OF BRIEFING DEADLINE

Appellant Texas Commission on Environmental Quality files this First Unopposed Motion for Extension of Briefing Deadline, pursuant to Rule 10.5(b) of the Texas Rules of Appellate Procedure, and in support thereof would respectfully show as follows: 1. There is no specific deadline to file this motion to extend time.

See Tex. R. App. P. 38.6(d).

2. The Court has the authority under Texas Rule of Appellate Procedure 38.6(d) to extend the time for Appellant to file this brief.

3. Appellant’s brief is currently due on Monday, January 5, 2026.

Tex. R. App. P. 38.6(b).

4. Counsel for Appellant seeks additional time to fully brief this matter. In addition to the briefing at issue for this Court, counsel for

Appellant has the following obligations surrounding the upcoming holiday season: 5. Among other matters, counsel for Appellant is engaged or has been engaged in preparing for various trial, litigation, and appellate deadlines in the following cases: State of California, et. al. v. U.S., et al., No. 4:25-cv-04966-HSG (N.D. Cal.), briefing due December 12, 2025; BAP Kennor Landfill, LLC v. Tex. Comm’n. on Env’tl Quality, No. D-1-GN-21-002747 (Travis County, Texas), briefing on jurisdictional plea due January 3, 2026 and hearing January 8, 2026; Tex. Comm’n. on Env’tl Quality v. Universal EV, LLC, No. D-1-GN-24- 004148 (Travis County, Texas), extensive discovery responses due January 12, 2026; Massey, et al., v. Tex. Comm’n. on Env’tl Quality, No. D-1-GN-21-002747 (Travis County, Texas), briefing due January 17, 2026.

6. Additionally, the Texas Supreme Court may soon request counsel for Appellant to respond to the Petition for Review filed in Richard M. Young, Jr. a/k/a Richard Young v. Tex. Parks & Wildlife Dep’t, et al., No 25-0628, waiver of response filed December 12, 2025.

7. Consequently, Appellant requests a 30-day extension of its briefing deadline to Wednesday, February 4, 2026, in order to ensure

there is adequate time to prepare briefing and filing and to provide the Court with a brief that will be helpful and best assist the Court’s decision-making process.

8. This is Appellant’s first request for an extension of time to file its brief.

9. Counsel for Appellant conferred with counsel for Appellees, on December 11-12, 2025. This motion for extension is unopposed. This extension is not sought for purposes of delay, but so that justice may be done.

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 KELLIE E. BILLINGS-RAY Chief, Environmental Protection Division /s/ Ian Lancaster IAN LANCASTER Assistant Attorney General State Bar No. 24097964 [email protected] OFFICE OF THE ATTORNEY GENERAL Environmental Protection Division P. O. Box 12548, MC-066 Austin, Texas 78711-2548 Tel: (512) 463-2012 | Fax: (512) 463-0911 COUNSEL FOR APPELLANT

Certificate of Conference As required by Texas Rule of Appellate Procedure 10.1(a)(5), the undersigned conferred with the listed counsel for Appellees regarding this motion on December 11-12, 2025, who advised that Appellees were unopposed to the motion and relief sought.

Certificate of Service I hereby certify that on this 12th day of December 2025, a true and correct copy of the foregoing has been served upon the parties listed below via electronic service or email.

SARAH JANE UTLEY Environmental Division Director [email protected] BETHANY DWYER Assistant County Attorney [email protected] RYAN COOPER Assistant County Attorney [email protected] HARRIS COUNTY ATTORNEY’S OFFICE 1019 Congress Avenue, 15th Floor Houston, Texas 77002 Telephone: (713) 274-5124 Facsimile: (713) 437-4211 AND Adam M. Friedman [email protected] Hailey Culhane [email protected] MCELROY, SULLIVAN, MILLER & WEBER, L.L.P. P.O. Box 12127 Austin, Texas 78711 Tel: (512) 327-8111 Fax: (512) 350-2681 COUNSEL FOR APPELLEE HARRIS COUNTY, TEXAS Amy Catherine Dinn [email protected] Caroline Crow [email protected] Noor Mozaffar [email protected] LONE STAR LEGAL AID EQUITABLE DEVELOPMENT INITIATIVE ENVIRONMENTAL JUSTICE TEAM 1415 Fannin Houston, Texas 77002 Ph. (713) 652-0077 ext. 8108 Fax (713) 652-3141 COUNSEL FOR APPELLEES SUPER NEIGHBORHOOD 48 TRINITY/ HOUSTON GARDENS, DYERSFOREST HEIGHTS CIVIC CLUB, AND PROGRESSIVE FIFTH WARD COMMUNITY ASSOCIATION

/s/ Ian Lancaster IAN LANCASTER

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.

James McCarley on behalf of Ian Lancaster Bar No. 24097964 [email protected] Envelope ID: 109032347 Filing Code Description: Motion Filing Description: Appellant's First Unopposed Motion for Extension of Briefing Deadline Status as of 12/12/2025 11:06 AM CST Associated Case Party: TEXAS COMMISSION ON ENVIRONMENTAL QUALITY Name BarNumber Email TimestampSubmitted Status Ian Lancaster [email protected] 12/12/2025 10:59:15 AM SENT James ScottMcCarley [email protected] 12/12/2025 10:59:15 AM SENT

Associated Case Party: Harris County, Texas Name BarNumber Email TimestampSubmitted Status Adam M.Friedman [email protected] 12/12/2025 10:59:15 AM SENT Hailey Culhane 24127440 [email protected] 12/12/2025 10:59:15 AM SENT Sarah J. Utley [email protected] 12/12/2025 10:59:15 AM SENT Ryan Cooper 24123649 [email protected] 12/12/2025 10:59:15 AM SENT Bethany Dwyer [email protected] 12/12/2025 10:59:15 AM SENT

Associated Case Party: Super Neighborhood 48 Trinity/Houston Gardens Name BarNumber Email TimestampSubmitted Status Amy Dinn [email protected] 12/12/2025 10:59:15 AM SENT Caroline Crow [email protected] 12/12/2025 10:59:15 AM SENT Noor Mozaffar [email protected] 12/12/2025 10:59:15 AM SENT