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ACCEPTED
15-25-00122-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
9/22/2025 5:58 PM
No. 15-25-00122-CV CHRISTOPHER A. PRINE
CLERK
IN THE COURT OF APPEALS FILED IN
FOR THE FIFTEENTH JUDICIAL DISTRICT15th COURT OF APPEALS
AUSTIN, TEXAS
AUSTIN, TEXAS 9/22/2025 5:58:44 PM
CHRISTOPHER A. PRINE
Clerk
STATE OF TEXAS, AND MAXX JUUSOLA, TRACY MARTIN, AND ALAN CRIDER,
Appellants,
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,
Appellees.

On Appeal from the
298th Judicial District Court, Dallas County
____________________________________________________

APPELLANT STATE OF TEXAS’S FIRST UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE BRIEF
____________________________________________________

TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

Appellant, State of Texas (“State”) by and through Ken Paxton, Attorney

General of Texas (Appellant), respectfully requests an extension of time to Friday,

October 23, 2025, in which to file its brief in the captioned appeal. In support, the

State would show the Court as follows:

1. Appellant’s brief is currently due on September 25, 2025. Appellant

requests an extension of twenty-eight days. No previous extensions have been

requested or granted.
2. Counsel for Appellant is in need of an extension due to emergent

matters that arose in other cases which required a majority of his time before

September 25, 2025.

3. This motion is not interposed for the purpose of delay, but only to allow

counsel for the State to adequately prepare and file its brief.

4. Counsel for each Appellee has stated they do not oppose this request.

Appellant State of Texas therefore respectfully requests an extension of time

to and including Friday, October 23, 2025, in which to file and serve its brief in the

captioned appeal.

DATED: September 22, 2025.

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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

ERNEST C. GARCIA
Chief, Administrative Law Division

/s/ Canon Parker Hill
CANON PARKER HILL
Assistant Attorney General
State Bar No. 24140247
OFFICE OF THE ATTORNEY GENERAL OF TEXAS
Administrative Law Division
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Telephone: (512) 936-1838
Facsimile: (512) 320-0167
Canon.hill@oag.texas.gov

Counsel for Appellant,
State of Texas

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CERTIFICATE OF CONFERENCE

I hereby certify that I contacted counsel Jeffery Tillotson for Appellee City of
Dallas and Kimberly Tolbert in her official capacity as interim city manager, and
counsel Jim Harris for Appellee State Fair of Texas, and that both counsels stated
they are unopposed to the extension requested in this Motion.

/s/ Canon Parker Hill
CANON PARKER HILL
Assistant Attorney General

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CERTIFICATE OF SERVICE

I hereby certify that, in compliance with Rule 9.5 of the Texas Rules of
Appellate Procedure, a true and correct copy of the above and foregoing document
has been served on the following on this the 4th day of November 2021:

Jeffrey Tillotson via e-service to: jtillotson@tillotsonlaw.com
Tillotson, Johnson & Patton
1201 Main Street, Suite 1300
Dallas, Texas 75202
Counsel for City of Dallas and
Kimberly Tolbert

Bryan Neal via e-service to: bryan.neal@hklaw.com
Holland & Knight
One Arts Plaza
1722 Routh Street, Suite 1500
Dallas, Texas 75201-2532
Counsel for State Fair of Texas

Tony K. McDonald via e-service to: Tony@tonymcdonald.com
State Bar No. 24083477
Connor Ellington via e-service to: connor@tonymcdonald.com
State Bar No. 24128592
The Law Offices of Tony McDonald
1308 Ranchers Legacy Trail
Fort Worth, TX 76126
Counsel for Individual Plaintiffs
/s/ Canon Parker Hill
CANON PARKER HILL
Assistant Attorney General

5
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.

Catherine Hughes on behalf of Canon Hill
Bar No. 24140247
catherine.hughes@oag.texas.gov
Envelope ID: 105930940
Filing Code Description: Motion
Filing Description: Motion for Extension
Status as of 9/23/2025 7:13 AM CST

Associated Case Party: City of Dallas

Name BarNumber Email TimestampSubmitted Status

Joseph AIrrobali airrobali@tillotsonlaw.com 9/22/2025 5:58:44 PM SENT

Nathaniel Buchheit nbuchheit@tillotsonlaw.com 9/22/2025 5:58:44 PM SENT

Megan Coker mcoker@tillotsonlaw.com 9/22/2025 5:58:44 PM SENT

Anne Johnson ajohnson@tillotsonlaw.com 9/22/2025 5:58:44 PM SENT

Jeffrey Tillotson 20039200 jtillotson@tillotsonlaw.com 9/22/2025 5:58:44 PM SENT

Associated Case Party: State Fair of Texas

Name BarNumber Email TimestampSubmitted Status

James Harris 9065400 jim.harris@hklaw.com 9/22/2025 5:58:44 PM SENT

Sherri Rodgers sherri.rodgers@hklaw.com 9/22/2025 5:58:44 PM SENT

Bryan Neal 788106 Bryan.Neal@hklaw.com 9/22/2025 5:58:44 PM SENT

Robert B.Smith Robert@Smith-Firm.com 9/22/2025 5:58:44 PM SENT

Associated Case Party: State of Texas

Name BarNumber Email TimestampSubmitted Status

Melissa Juarez melissa.juarez@oag.texas.gov 9/22/2025 5:58:44 PM SENT

Meridith Fischer Meridith.Fischer@oag.texas.gov 9/22/2025 5:58:44 PM SENT

Ernest Garcia ernest.garcia@oag.texas.gov 9/22/2025 5:58:44 PM SENT

Catherine Hughes catherine.hughes@oag.texas.gov 9/22/2025 5:58:44 PM SENT

Canon ParkerHill canon.hill@oag.texas.gov 9/22/2025 5:58:44 PM SENT

Steven Ogle Steven.Ogle@oag.texas.gov 9/22/2025 5:58:44 PM SENT
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.

Associated Case Party: State of Texas

Steven Ogle Steven.Ogle@oag.texas.gov 9/22/2025 5:58:44 PM SENT

Holly Dudrick holly.dudrick@oag.texas.gov 9/22/2025 5:58:44 PM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Kira Lytle klytle@tillotsonlaw.com 9/22/2025 5:58:44 PM SENT

TJP Service tillotsonjohnsonpatton@gmail.com 9/22/2025 5:58:44 PM SENT

William Cole William.Cole@oag.texas.gov 9/22/2025 5:58:44 PM SENT

William Peterson William.Peterson@oag.texas.gov 9/22/2025 5:58:44 PM SENT

Bryan Neal bryan.neal@hklaw.com 9/22/2025 5:58:44 PM SENT

Tony McDonald Tony@tonymcdonald.com 9/22/2025 5:58:44 PM SENT

Devlin Browne dbrowne@tillotsonlaw.com 9/22/2025 5:58:44 PM SENT

Associated Case Party: AlanCrider

Name BarNumber Email TimestampSubmitted Status

Connor Ellington connor@tonymcdonald.com 9/22/2025 5:58:44 PM SENT

Associated Case Party: MaxxJuusola

Name BarNumber Email TimestampSubmitted Status

Connor Ellington connor@tonymcdonald.com 9/22/2025 5:58:44 PM SENT

Associated Case Party: TracyMartin
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.

Associated Case Party: TracyMartin

Name BarNumber Email TimestampSubmitted Status

Connor Ellington connor@tonymcdonald.com 9/22/2025 5:58:44 PM SENT

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

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