Court of Civil Appeals of Texas, 2025

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

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
Court of Civil Appeals of Texas · Decided December 11, 2025

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

Opinion

ACCEPTED 15-25-00022-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 12/11/2025 11:42 AM No. 15-25-00022-CV CHRISTOPHER A. PRINE CLERK In the Court of Appeals FILED IN 15th COURT OF APPEALS For the Fifteenth Judicial District of Texas AUSTIN, TEXAS 12/11/2025 11:42:20 AM CHRISTOPHER A. PRINE CITY OF COPPEL, TEXAS, ET AL., Clerk Appellants/Cross-Appellees, v. KELLY HANCOCK, ACTING COMPTROLLER OF PUBLIC ACCOUNTS OF THE STATE OF TEXAS, Appellee/Cross-Appellant.

On Appeal from the 201st Judicial District Court, Travis County, Texas Cause No. D-1-GN-21-003198; consolidated with D-1-GN-21-003203 Appellants’ and Cross-Appellant’s Joint Motion to Extend Time to File Reply Briefs James B. Harris KEN PAXTON State Bar No. 09065400 Attorney General of Texas [email protected] BRENT WEBSTER Stephen F. Fink First Assistant Attorney General State Bar No. 07013500 RALPH MOLINA [email protected] Deputy First Assistant Attorney General Richard B. Phillips, Jr. AUSTIN KINGHORN State Bar No. 24032833 Deputy Attorney General for Civil Litigation [email protected] STEVEN ROBINSON Division Chief, Tax Litigation Division Holland & Knight LLP KYLE PIERCE COUNCE 1722 Routh Street, Suite 1500 State Bar No. 24082862 Dallas, Texas 75201 [email protected] Phone: (214) 964-9500 Assistant Attorney General Tax Litigation Division Counsel for Coppell P. O. Box 12548 Parties Austin, Texas 78711-2548 Phone: (512) 463-3112 Counsel for Comptroller

Page 1 of 6 To the Honorable Court of Appeals: 1. Under Texas Rules of Appellate Procedure 2, 10.5(b), and 38.6(d), Appellants City Coppell, Texas, City of Humble, Texas, City of DeSoto, Texas, City of Carrollton, Texas, and City of Farmers Branch, Texas (the “Coppell Parties”) and Cross-Appellant Kelly Hancock, in his official capacity as Acting Comptroller of Public Accounts of the State of Texas (the “Comptroller”) respectfully request a 30- day extension on the due dates for their reply 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. The Coppell Parties’ reply brief as appellants and Comptroller’s reply briefs as cross-appellant are currently due on Monday, December 29, 2025. The requested extension would make the briefs due on Wednesday, January 28, 2026.1 3. The Comptroller is not opposed to the requested extension of the due date for the Coppell Parties’ reply brief. The Coppell Parties are not opposed to the requested

The reply briefs would have normally been due December 26, 2025. We understand the Court, consistent with the holiday schedule set by the State Auditor’s Office, recognizes December 25-26, 2025, as holidays meaning the reply briefs would be due Monday December 29, 2025, because the 26th is a Friday. Thirty days from December 29, 2025, falls on Wednesday January 28, 2026.

Page 2 of 6 extension of the due date for the Comptroller’s reply briefs. And counsel for Appellee the City of Round Rock, Texas has indicated that the City of Round Rock is not opposed to the Comptroller’s or Coppell Parties’ requested extensions.2 4. The Coppell Parties request this extension because their counsel has been and will be occupied with other matters that will prevent them from filing the reply brief by the current due date. Among other matters, counsel has been occupied with the following: a. Preparing for and presenting oral argument on December 2, 2025, in No. 23-0671, Johnson v. Clifton, pending in the Supreme Court of Texas; b. Preparing the response brief of appellee Superior HealthPlan, Inc., due on December 9, 2025, in No. 15-24-00114-CV, Cecile E. Young, in Her Official Capcity as Executive Commissioner of the Texas Health & Human Services Commission v. Cook Children’s Health Plan, et al., pending in this Court; c. Prepare the appellant’s reply brief currently due on December 23, 2025, in No. 10-25-00088-CV, In re Estate of Christopher James Kling, Deceased, and No. 10-25-00089-CV, In re Guardianship of Christopher James Kling, pending in the Court of Appeals for the Tenth District of Texas; and d. Prepare the response brief of appellee State Fair of Texas due January 9, 2026 in 15-25-00122-CV, 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, pending in this court.

The City of Round Rock did not appeal the final judgment and therefore its only capacity in this Court is as an appellee as to the Comptroller’s cross-appeal.

Page 3 of 6 5. The Comptroller requests this extension because their counsel has been and will be occupied with other matters that will prevent them from filing the reply briefs by the current due date. Among other matters, counsel has been occupied with the following: a. Preparing for a hearing on a Plea to the Jurisdiction, set for December 11, 2025, in Cause No. D-1-GN-22-006621, Brad Wayne Keaton v. Texas Workforce Commission, pending in the 459th District Court of Travis County, Texas; b. Preparing for hearing on a Cross Motion for Summary Judgment to be argued on December 15, 2025 in Cause No. D-1-GN-22-004846, Quanta Services, Inc. v. Glenn Hegar, as Comptroller of Public Accounts of Texas, and Ken Paxton, Attorney General of Texas, pending in the 200th District Court of Travis County, Texas; c. Preparing a Cross Motion for Summary Judgment to be filed by January 12, 2026, in Cause No. D-1-GN-24-001871, Hessonite [MF] Non-REIT LLC, v. Kelly Hancock, Acting Texas Comptroller of Public Accounts, and the Office of the Comptroller of Public Accounts of Texas, Liza pending in the 419th District Court of Travis County, Texas; and d. Assisting with oral argument, set for January 21, 2026, in Cause No. 15- 25-00041-CV, Appraisal Review Board of the Harris County Appraisal District v. Texas Workforce Commission and Redona Hall, pending the before this Court.

Therefore, the Coppell Parties and the Comptroller request that the Court extend the deadline for their opening briefs to Wednesday, January 28, 2026. The Coppell Parties and the Comptroller further request general relief.

Dated: December 11, 2025

Page 4 of 6 Respectfully submitted,

HOLLAND & KNIGHT LLP KEN PAXTON Attorney General of Texas By: /s/ Richard B. Phillips, Jr.___ BRENT WEBSTER James B. Harris First Assistant Attorney General State Bar No. 09065400 [email protected] RALPH MOLINA Deputy First Assistant Attorney Stephen F. Fink General State Bar No. 07013500 [email protected] AUSTIN KINGHORN Richard B. Phillips, Jr. Deputy Attorney General for Civil State Bar No. 24032833 Litigation [email protected] STEVEN ROBINSON 1722 Routh Street, Suite 1500 Division Chief, Tax Litigation Division Dallas, Texas 75201 Phone: (214) 964-9500 /s/ Peter N. Berquist______ Kyle Pierce Counce COUNSEL FOR COPPELL State Bar No. 24082862 PARTIES T: (512) 463-3112 [email protected] Assistant Attorney General PETER N. BERQUIST State Bar No. 24131255 T: (512) 936-1383 [email protected] Assistant Attorney General Tax Litigation Division P. O. Box 12548 Austin, Texas 78711-2548 F: (512) 478-4013 ATTORNEYS FOR COMPTROLLER

Page 5 of 6 CERTIFICATE OF CONFERENCE Counsel for the Comptroller discussed this motion with Cindy Olson Bourland, counsel for Appellee the City of Round Rock, Texas by email, who indicated that the City of Round Rock, Texas is not opposed to the requested extension.

/s/ Kyle Pierce Counce Kyle Pierce Counce Deputy Division Chief

Page 6 of 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.

Lynee Pearson on behalf of Kyle Counce Bar No. 24082862 [email protected] Envelope ID: 108986067 Filing Code Description: Motion Filing Description: 20251211 Joint Motion to Extend Replies Status as of 12/11/2025 11:51 AM CST Associated Case Party: City of Coppell, Texas Name BarNumber Email TimestampSubmitted Status Richard Phillips 24032833 [email protected] 12/11/2025 11:42:20 AM SENT Reed Randel 24075780 [email protected] 12/11/2025 11:42:20 AM SENT Stephen Fink 7013500 [email protected] 12/11/2025 11:42:20 AM SENT James Harris 9065400 [email protected] 12/11/2025 11:42:20 AM SENT

Case Contacts Name BarNumber Email TimestampSubmitted Status Bryan Dotson 24072769 [email protected] 12/11/2025 11:42:20 AM SENT Cynthia Bourland 790343 [email protected] 12/11/2025 11:42:20 AM SENT Brandon L.King [email protected] 12/11/2025 11:42:20 AM SENT

Associated Case Party: Glenn Hegar, in his official capacity as Texas Comptroller of Public Accounts Name BarNumber Email TimestampSubmitted Status Ray Langenberg 11911200 [email protected] 12/11/2025 11:42:20 AM SENT Kyle Counce 24082862 [email protected] 12/11/2025 11:42:20 AM SENT

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