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
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
james.harris@hklaw.com BRENT WEBSTER
Stephen F. Fink First Assistant Attorney General
State Bar No. 07013500 RALPH MOLINA
stephen.fink@hklaw.com Deputy First Assistant Attorney General
Richard B. Phillips, Jr. AUSTIN KINGHORN
State Bar No. 24032833 Deputy Attorney General for Civil Litigation
rich.phillips@hklaw.com 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 kyle.counce@oag.texas.gov
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

1
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.

2
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
james.harris@hklaw.com RALPH MOLINA
Deputy First Assistant Attorney
Stephen F. Fink General
State Bar No. 07013500
stephen.fink@hklaw.com AUSTIN KINGHORN
Richard B. Phillips, Jr. Deputy Attorney General for Civil
State Bar No. 24032833 Litigation
rich.phillips@hklaw.com
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
kyle.counce@oag.texas.gov
Assistant Attorney General
PETER N. BERQUIST
State Bar No. 24131255
T: (512) 936-1383
Peter.Berquist@oag.texas.gov
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
lynee.pearson@oag.texas.gov
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 Rich.Phillips@hklaw.com 12/11/2025 11:42:20 AM SENT

Reed Randel 24075780 Reed.Randel@hklaw.com 12/11/2025 11:42:20 AM SENT

Stephen Fink 7013500 Stephen.Fink@hklaw.com 12/11/2025 11:42:20 AM SENT

James Harris 9065400 jim.harris@hklaw.com 12/11/2025 11:42:20 AM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Bryan Dotson 24072769 bryan.dotson@chamberlainlaw.com 12/11/2025 11:42:20 AM SENT

Cynthia Bourland 790343 bourland@bourlandlaw.com 12/11/2025 11:42:20 AM SENT

Brandon L.King brandon.king@hklaw.com 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 ray.langenberg@cpa.texas.gov 12/11/2025 11:42:20 AM SENT

Kyle Counce 24082862 Kyle.Counce@oag.texas.gov 12/11/2025 11:42:20 AM SENT