Kelly Hancock, Acting Texas Comptroller of Public Accounts of the State of Texas, and Ken Paxton, Attorney General of the State of Texas v. ChampionX, LLC

Print or Print to SAVE AS PDF. ACCEPTED
15-25-00143-CV
Appellate Docket Number: 15-25-00143-CV FIFTEENTH COURT OF APPEALS
Appellate Case Style: Kelly Hancock, Acting Texas Comptroller of Public Accounts of the StateAUSTIN,
of Texas,TEXAS
et al.
Vs. ChampionX, LLC 9/18/2025 11:14 AM
Companion Appellate Docket Number 15-24-00111-CV filed in the Fifteenth Court CHRISTOPHER
of Appeals of TexasA. PRINE
Case(s): CLERK
Amended/Corrected Statement FILED IN
15th COURT OF APPEALS
DOCKETING STATEMENT (Civil) AUSTIN, TEXAS
Appellate Court: 15th Court of Appeals 9/18/2025 11:14:16 AM
(to be filed in the court of appeals upon perfection of appeal under TRAP 32) A. PRINE
CHRISTOPHER
Clerk
NOTE: Because space for additional parties / attorneys is limited on this form, you can include the information on a separate document. As per TRAP
32.1 and 9.4, please include party’s name and the name, address, email address, telephone number, fax number, if any, and State Bar Number of the
party’s lead counsel. If the party is not represented by an attorney, that party’s name, address, telephone number, fax number should be provided.

I. Appellant II. Appellant Attorney(s) - Continued
Person Organization Lead Attorney Select
Name: Kelly Hancock, Comptroller of Public Accounts, et al. Name:
Pro Se Bar No.
If Pro Se Party, enter the following information: Firm/Agency:
Address: Address 1:
City/State/Zip: Address 2:
Tel. Ext. Fax: City/State/Zip:
Email: Tel. Ext. Fax:
II. Appellant Attorney(s) Email:
Lead Attorney Retained Attorney
Lead Attorney Select
Name: Kyle Pierce Counce Name:
Bar No. 24082862
Bar No.
Firm/Agency: Texas Attorney General
Firm/Agency:
Address 1: P.O. Box 12548 Address 1:
Address 2:
Address 2:
City/State/Zip: Austin, Texas 78711 City/State/Zip:
Tel. (512) 463-3312 Ext. Fax: (512) 478-4013
Tel. Ext. Fax:
Email: kyle.counce@oag.texas.gov
Email:
Lead Attorney Select
Lead Attorney Select
Name:
Name:
Bar No.
Bar No.
Firm/Agency:
Firm/Agency:
Address 1:
Address 1:
Address 2:
Address 2:
City/State/Zip:
City/State/Zip:
Tel. Ext. Fax:
Tel. Ext. Fax:
Email:
Email:

Page 1 of 11
III. Appellee IV. Appellee Attorney(s) - Continued
Person Organization Lead Attorney Retained Attorney
Name: ChampionX, LLC Name: Antoinette L. Ellison
Pro Se Bar No.
If Pro Se Party, enter the following information: Firm/Agency: Jones Day
Address: Address 1: 1420 Peachtree Street NE
City/State/Zip: Address 2: Suite 800
Tel. Ext. Fax: City/State/Zip: Atlanta, Georgia 30309
Email: Tel. (404) 581-8801 Ext. Fax:
Email: aellison@jonesday.com
IV. Appellee Attorney(s)
Lead Attorney Retained Attorney Lead Attorney Select

Name: Deborah S. Sloan Name:
Bar No. 00786230 Bar No.
Firm/Agency: Jones Day Firm/Agency:
Address 1: 2727 N. Harwood Street Address 1:
Address 2: Suite 500 Address 2:
City/State/Zip: Dallas, Texas 75201 City/State/Zip:
Tel. (214) 969-5203 Ext. Fax: Tel. Ext. Fax:
Email: dsloan@jonesday.com Email:

Lead Attorney Retained Attorney Lead Attorney Select

Name: John M. Allan Name:
Bar No. Bar No.
Firm/Agency: Jones Day Firm/Agency:
Address 1: 1420 Peachtree Street NE Address 1:
Address 2: Suite 800 Address 2:
City/State/Zip: Atlanta, Georgia 30309 City/State/Zip:
Tel. (404) 581-8012 Ext. Fax: Tel. Ext. Fax:
Email: jmallan@jonesday.com Email:

Page 2 of 11
V. Perfection of Appeal, Judgment and Sentencing
Nature of Case (Subject matter or type of case): Tax
Date Order or Judgment signed: 07/30/2025 Type of Judgment: Summary Judgment
Date Notice of Appeal filed in Trial Court: 08/28/2025
If mailed to the Trial Court clerk, also give the date mailed:
Interlocutory appeal of appealable order: Yes No
If yes, please specify statutory or other basis on which interlocutory order is appealable (See TRAP 28):

Accelerated Appeal (See TRAP 28): Yes No
If yes, please specify statutory or other basis on which appeal is accelerated:

Parental Termination or Child Protection? (See TRAP 28.4): Yes No
Permissive? (See TRAP 28.3): Yes No
If yes, please specify statutory or other basis for such status:

Agreed? (See TRAP 28.2): Yes No
If yes, please specify statutory or other basis for such status:

Appeal should receive precedence, preference, or priority under statute or rule? Yes No
If yes, please specify statutory or other basis for such status:

Does this case involve an amount under $100,000? Yes No
Judgment or Order disposes of all parties and issues? Yes No
Appeal from final judgment? Yes No
Does the appeal involve the constitutionality or the validity of a statute, rule, or ordinance? Yes No
If yes, you must also complete and file the Challenge to Constitutionality of a State Statute form.
If yes, is the Attorney General of Texas a party to the case? Yes No

VI. Actions Extending Time to Perfect Appeal
Motion for New Trial: Yes No If yes, date filed:
Motion to Modify Judgment: Yes No If yes, date filed:
Request for Findings of Fact and Conclusions of Law: Yes No If yes, date filed:
Motion to Reinstate: Yes No If yes, date filed:
Motion under TRCP 306a: Yes No If yes, date filed:
Other: Yes No
If Other, please specify:

Page 3 of 11
VII. Indigency of Party (Attach file stamped copy of Statement and copy of the trial court order.)
Was Statement of Inability to Pay Court Costs filed in the trial court? Yes No
If yes, date filed:
Was a Motion Challenging the Statement filed in the trial court? Yes No
If yes, date filed:
Was there any hearing on appellant’s ability to afford court costs? Yes No
Hearing Date:
Did trial court sign an order under Texas Rule of Civil Procedure 145? Yes No

Date of Order:
If yes, trial court finding: Challenge Sustained Overruled
VIII. Bankruptcy
Has any party to the court’s judgment filed for protection in bankruptcy which might affect this appeal?
Yes No
If yes, please attach a copy of the petition.
Date bankruptcy filed:
Bankruptcy Case Number:

IX. Trial Court and Record
Court: 53rd District Court Clerk’s Record
County: Travis Trial Court Clerk: ✔ District County
Trial Court Docket No. (Cause No.): Was Clerk’s record requested? Yes ✔ No
D-1-GN-23-000226
If yes, date requested:
Trial Court Judge (who tried or disposed of the case): If no, date it will be requested: 09/18/2025
Name: Honorable Ravi K. Sandill
Were payment arrangements made with clerk?
Address 1: 1700 Guadalupe Street
Yes ✔ No Indigent
Address 2: 8th Floor
(Note: No request required under TRAP 34.5(a),(b).)
City/State/Zip: Austin, Texas 78701
Tel. (512) 854-9308 Ext. Fax: (512) 854-9332
Email:

Page 4 of 11
IX. Trial Court and Record - Continued
Reporter’s or Recorder’s Record
Is there a Reporter’s Record? Yes No
Was Reporter’s Record requested? Yes No
If yes, date requested:
If no, date it will be requested:
Was the Reporter’s Record electronically recorded? Yes No
Were payment arrangements made with the court reporter/court recorder? Yes No Indigent

Court Reporter Court Recorder Court Reporter Court Recorder
Official Substitute Official Substitute
Name: Name:
Address 1: Address 1:
Address 2: Address 2:
City/State/Zip: City/State/Zip:
Tel. Ext. Fax: Tel. Ext. Fax:
Email: Email:

X. Supersedeas Bond
Supersedeas bond filed? Yes No
If yes, date filed:
If no, will file? Yes No

XI. Extraordinary Relief
Will you request extraordinary relief (e.g., temporary or ancillary relief) from this Court? Yes No
If yes, briefly state the basis for your request:
Parties will file a joint motion to abate.

Page 5 of 11
XII. Alternative Dispute Resolution/Mediation
(Complete section if filing in the 1st, 2nd, 4th, 5th, 6th, 8th, 10th, 11th, 13th, or 14th Court of Appeals.)
Should this appeal be referred to mediation? Yes No
If no, please specify:
Has this case been through an ADR procedure? Yes No
If yes, who was the mediator?
What type of ADR procedure?
At what stage did the case go through ADR? Pre-Trial Post-Trial Other
If other, please specify:
Type of Case? Tax
Give a brief description of the issue to be raised on appeal, the relief sought, and the applicable standard for review, if
known (without prejudice to the right to raise additional issues or request additional relief):
Construction of sales tax statute. Appellant requests reverse and render. Standard of review is de novo.

How was the case disposed of? After summary judgment, the trial court signed a final judgment.
Summary of relief granted, including amount of money judgment, and if any, damages awarded.
If money judgment, what was the amount? Actual damages: $ 185,038.50
Punitive (or similar) damages:
Attorney’s fees (trial):
Attorney’s fees (appellate):
Other:
If other, please specify:
Will you challenge this Court’s jurisdiction? Yes No
Does judgment have language that one or more parties “take nothing”? Yes No
Does judgment have a Mother Hubbard clause? Yes No
Other basis for finality:

Page 6 of 11
XII. Alternative Dispute Resolution/Mediation - Continued
(Complete section if filing in the 1st, 2nd, 4th, 5th, 6th, 8th, 10th, 11th, 13th, or 14th Court of Appeals.)
Rate the complexity of the case (use 1 for least and 5 for most complex): 1 2 3 4 5
Please make my answer to the preceding questions known to other parties in this case? Yes No
Can the parties agree on an appellate mediator? Yes No
If yes, please give the name, address, telephone, fax, and email address:
Name:
Address:
Telephone: Ext.
Fax:
Email:
Languages other than English in which the mediator should be proficient:

Name of the person filling out mediation section of docketing statement:

XIII. Related Matters
List any pending or past related appeals before this, or any other Texas Appellate Court, by Court, Docket, and Style.
Court: Select Appellate Court Docket: 15-25-00111-CV
Style: Glenn Hegar, Comptroller of Public Accounts of the State of Texas, and Ken Paxton, Attorney General of the State of Texas
Vs. ChampionX, LLC (NOTE - Cannot select 15th COA in drop down list)
Court: Select Appellate Court Docket:
Style:
Vs.
Court: Select Appellate Court Docket:
Style:
Vs.
Court: Select Appellate Court Docket:
Style:
Vs.
Court: Select Appellate Court Docket:
Style:
Vs.
Court: Select Appellate Court Docket:
Style:
Vs.

Page 7 of 11
XIV. Pro Bono Program:
(Complete section if filing in the 1st, 2nd, 3rd, 5th, 7th, 13th or 14th Court of Appeals.)
The Courts of Appeals listed above, in conjunction with the State Bar of Texas Appellate Section Pro Bono Committee
and local Bar Associations, are conducting a program to place a limited number of civil appeals with appellate counsel
who will represent the appellant in the appeal before this Court.
The Pro Bono Committee is solely responsible for screening and selecting the civil cases for inclusion in the Program
based upon a number of discretionary criteria, including the financial means of the appellant or appellee. If a case is
selected by the Committee, and can be matched with appellate counsel, that counsel will take over representation of the
appellant or appellee without charging legal fees. More information regarding this program can be found in the Pro Bono
Program Pamphlet available in paper form at the Clerk's Office or on the Internet at http://www.tex-app.org. If your case
is selected and matched with a volunteer lawyer, you will receive a letter from the Pro Bono Committee within thirty (30)
to forty-five (45) days after submitting this Docketing Statement.
Note: there is no guarantee that if you submit your case for possible inclusion in the Pro Bono Program, the Pro Bono
Committee will select your case and that pro bono counsel can be found to represent you. Accordingly, you should not
forego seeking other counsel to represent you in this proceeding. By signing your name below, you are authorizing the
Pro Bono committee to transmit publicly available facts and information about your case, including parties and
background, through selected Internet sites and Listserv to its pool of volunteer appellate attorneys.
Do you want this case to be considered for inclusion in the Pro Bono Program? Yes No
Do you authorize the Pro Bono Committee to contact your trial counsel of record in this matter to answer questions the
committee may have regarding the appeal? Yes No
Please note that any such conversations would be maintained as confidential by the Pro Bono Committee and the
information used solely for the purposes of considering the case for inclusion in the Pro Bono Program.
If you have not previously filed a Statement of Inability to Pay Court Costs and attached a file-stamped copy of that
Statement, does your income exceed 200% of the U.S. Department of Health and Human Services Federal Poverty
Guidelines? Yes No
These guidelines can be found in the Pro Bono Program Pamphlet as well as on the internet at
http://aspe.hhs.gov/poverty/06poverty.shtml.
Are you willing to disclose your financial circumstances to the Pro Bono Committee? Yes No
If yes, please attach a Statement of Inability to Pay Court Costs completed and executed by the appellant or appellee.
Sample forms may be found in the Clerk's Office or on the internet at http://www.tex-app.org. Your participation in
the Pro Bono Program may be conditioned upon your execution of a Statement under oath as to your financial
circumstances.

Give a brief description of the issues to be raised on appeal, the relief sought, and the applicable standard of review, if
known (without prejudice to the right to raise additional issues or request additional relief; use a separate attachment, if
necessary).

Page 8 of 11
XV. Fifteenth Court of Appeals Jurisdiction
Effective 9/1/24, certain cases filed with this court must be transferred to the new Fifteenth Court of Appeals (See SB
1045, 88th Legislature, Regular Session). To assist the court in the orderly transfer or cases, please complete the
following information.
Does this appeal involve a matter brought by or against the state or a board, commission, department, office, or other
agency in the executive branch of the state government, including a university system or institution of higher education
as defined by Section 61.003, Education Code, or by or against an officer or employee of the state or a board,
commission, department, office, or other agency in the executive branch of the state government arising out of that
officer ’s or employee ’s official conduct? Yes No
If the answer is yes, does this appeal involve:
a proceeding brought under the Family Code and any related motion or proceeding;
a proceeding brought under Chapter 7B or Article 17.292, Code of Criminal Procedure;
a proceeding brought against a district attorney, a criminal district attorney, or a county attorney with criminal
jurisdiction;
a proceeding relating to a mental health commitment;
a proceeding relating to civil asset forfeiture;
a condemnation proceeding for the acquisition of land or a proceeding related to eminent domain;
a proceeding brought under Chapter 101, Civil Practice and Remedies Code;
a claim of personal injury or wrongful death;
a proceeding brought under Chapter 125, Civil Practice and Remedies Code, to enjoin a common nuisance;
a proceeding brought under Chapter 55, Code of Criminal Procedure;
a proceeding under Chapter 22A, Government Code;
a proceeding brought under Subchapter E-1, Chapter 411, Government Code;
a proceeding brought under Chapter 21, Labor Code;
a removal action under Chapter 87, Local Government Code;
a proceeding brought under Chapter 841, Health and Safety Code;

XVI. Signature
09/18/2025
Signature of counsel (or Pro Se Party) Date
Kyle Pierce Counce 24082862
Printed Name State Bar No.
/s/ Kyle Pierce Counce
Electronic Signature (Optional) Name

XVII. Certificate of Service
The undersigned counsel certifies that this Docketing Statement has been served on the following lead counsel for all
parties to the Trial Court’s Order or Judgment as follows on:
/s/ Kyle Pierce Counce
Signature of counsel (or Pro Se Party) Electronic Signature (Optional)

24082862
State Bar No.

Certificate of Service Requirements (TRAP 9.5(e)): A certificate of service must be signed by the person who made the service and
must state:
(1) the date and manner of service;
(2) the name and address of each person served, and
(3) if the person served is a party’s attorney, the name of the party represented by the attorney.

Page 9 of 11
Please enter the following for each person served:
Date Served: 09/18/2025 Date Served:
Manner Served: eServe Manner Served: Select
Name: Deborah S. Sloan Name:
Bar No. 00786230 Bar No.
Firm/Agency: Jones Day Firm/Agency:
Address 1: 2727 N Harwood Street Address 1:
Address 2: Suite 500 Address 2:
City/State/Zip: Dallas, Texas 75201 City/State/Zip:
Tel. (214) 969-5203 Ext. Fax: Tel. Ext. Fax:
Email: dsloan@jonesday.com Email:
Party: Plaintiff Party:

Date Served: 09/18/2025 Date Served:
Manner Served: eServe Manner Served: Select
Name: John M. Allan Name:
Bar No. Bar No.
Firm/Agency: Jones Day Firm/Agency:
Address 1: 1420 Peachtree Street NE Address 1:
Address 2: Suite 800 Address 2:
City/State/Zip: Atlanta, Georgia 30309 City/State/Zip:
Tel. (404) 581-8012 Ext. Fax: Tel. Ext. Fax:
Email: jmallan@jonesday.com Email:
Party: Plaintiff Party:

Date Served: 09/18/2025
Manner Served: eServe
Name: Antoinette L. Ellison
Bar No.
Firm/Agency: Jones Day
Address 1: 1420 Peachtree Street NE
Address 2: Suite 800
City/State/Zip: Atlanta, Georgia 30309
Tel. (404) 581-8801 Ext. Fax:
Email: aellison@jonesday.com
Party: Plaintiff

Page 10 of 11
Please enter the following for each person served that is not an attorney for a party:
Date Served: Date Served:
Manner Served: Select Manner Served: Select
Name: Name:
Address 1: Address 1:
Address 2: Address 2:
City/State/Zip: City/State/Zip:
Tel. Ext. Tel. Ext.
Fax: Fax:
Email: Email:

Date Served: Date Served:
Manner Served: Select Manner Served: Select
Name: Name:
Address 1: Address 1:
Address 2: Address 2:
City/State/Zip: City/State/Zip:
Tel. Ext. Tel. Ext.
Fax: Fax:
Email: Email:

Date Served: Date Served:
Manner Served: Select Manner Served: Select
Name: Name:
Address 1: Address 1:
Address 2: Address 2:
City/State/Zip: City/State/Zip:
Tel. Ext. Tel. Ext.
Fax: Fax:
Email: Email:

Print or Print to SAVE AS PDF.

Page 11 of 11
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: 105766114
Filing Code Description: Docketing Statement
Filing Description: 20250918 Docketing Statement
Status as of 9/18/2025 12:01 PM CST

Associated Case Party: Kelly Hancock Comptroller of Texas

Name BarNumber Email TimestampSubmitted Status

Kyle PierceCounce kyle.counce@oag.texas.gov 9/18/2025 11:14:16 AM SENT

Associated Case Party: ChampionX, LLC

Name BarNumber Email TimestampSubmitted Status

Deborah S.Sloan dsloan@jonesday.com 9/18/2025 11:14:16 AM SENT