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

ACCEPTED
15-25-00122-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
11/18/2025 3:12 PM
15-25-00122-CV CHRISTOPHER A. PRINE
CLERK
In the Court of Appeals FILED IN
15th COURT OF APPEALS
for the Fifteenth District of Texas AUSTIN, TEXAS
11/18/2025 3:12:04 PM
State of Texas, Maxx Juusola, Tracy Martin, and Alan Crider,
CHRISTOPHER A. PRINE
Clerk
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.

Appellee State Fair of Texas’s Unopposed Motion
for Extension of Time to File Brief

James B. Harris Robert B. Smith
State Bar No. 09065400 State Bar No. 00786248
Jim.Harris@hklaw.com Robert@Smith-Firm.com
Bryan P. Neal Two Turtle Creek Village
State Bar No. 00788106 3838 Oak Lawn Ave., Suite 1000
Bryan.Neal@hklaw.com Dallas, Texas 75219
Dina W. McKenney Phone: (214) 522-5571
State Bar No. 24092809 Fax: (214) 522-5009
Dina.McKenney@hklaw.com

Holland & Knight LLP
One Arts Plaza
1722 Routh Street, Suite 1500
Dallas, Texas 75201
Phone: 214-969-1700
Fax: 214-964-9501

Counsel for Appellee State Fair of Texas
To The Honorable Court of Appeals:

Appellee State Fair of Texas (“SFOT”) respectfully requests an

extension of time to Friday, January 9, 2026, in which to file its brief in the

captioned appeal. In support, SFOT states as follows:

1. SFOT’s brief is currently due on November 24, 2025.

2. SFOT requests a 46-day extension of time to file its brief. The

requested extension of time would make SFOT’s brief due on January 9, 2026.

3. This is SFOT’s first request for an extension of time to file its

brief.

4. Appellant State of Texas does not oppose this requested

extension.

5. While SFOT would normally request a 30-day extension of time

to file its brief, such an extension would make the brief due on Christmas Eve.

SFOT requests 46-day extension of time to avoid the deadline falling in the

middle of the winter holidays, which also will prevent Appellant’s reply

deadline from beginning to run during that time.

6. SFOT requests this extension of time because counsel needs

additional time to prepare its brief. Specifically, among other matters, counsel

for SFOT has been and will be occupied with the following matters that will

Appellee State Fair of Texas’s Unopposed Motion
for Extension of Time to File Brief —Page 1
prevent them from dedicating the time necessary to complete the brief before

the current deadline:

(a) Prepare for temporary injunction hearing in Hicks v.
National Collegiate Athletic Association, No. 25CVDC-
00292, pending in the 266th Judicial District, Erath
County;

(b) Prepare appellate brief due on December 2, 2025, in
National Collegiate Athletic Association v. Agee, No. 10-
25-00399-CV, pending in the Tenth Court of Appeals;

(c) Prepare appellate brief due on December 3, 2025, in
National Collegiate Athletic Association v. Moore, No.
05-25-1375-CV, pending in the Fifth Court of Appeals;

(d) Prepare appellate brief due on December 15, 2025, in
National Collegiate Athletic Association v. Moore, No.
05-25-1361-CV, pending in the Fifth Court of Appeals;
and

(e) Prepare response to the complaint due on December 16,
2025 in Guillory v. 3M Company, et al., No. 2510035695,
pending in the Court of Common Pleas, Philadelphia
County, Pennsylvania.

7. Additionally, one of SFOT’s counsel has a pre-planned vacation

from December 10 to December 15, 2025.

8. As a result, SFOT needs additional time to prepare its brief.

SFOT respectfully requests this Court extend the deadline for its brief

to January 9, 2026. SFOT further requests general relief.

Appellee State Fair of Texas’s Unopposed Motion
for Extension of Time to File Brief —Page 2
Respectfully submitted:

/s/ Bryan P. Neal
James B. Harris
Texas Bar No. 09065400
Bryan P. Neal
Texas Bar No. 00788106
Dina W. McKenney
Texas Bar No. 24092809
HOLLAND & KNIGHT LLP
One Arts Plaza
1722 Routh Street, Suite 1500
Dallas, Texas 75201
(214) 969-1700
(214) 964-9501 (Fax)
Jim.Harris@hklaw.com
Bryan.Neal@hklaw.com
Dina.McKenney@hklaw.com

Robert B. Smith
Texas Bar No. 00786248
Two Turtle Creek Village
3838 Oak Lawn Ave., Suite 1000
Dallas, Texas 75219
(214) 522-5571
(214) 522-5009 (Fax)
Robert@Smith-Firm.com

ATTORNEYS FOR APPELLEE
STATE FAIR OF TEXAS

Appellee State Fair of Texas’s Unopposed Motion
for Extension of Time to File Brief —Page 3
CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoing was filed and
served electronically through eFile.TXCourts.gov this 18th day of November
2025, on all counsel of record.

/s/ Bryan P. Neal
Bryan P. Neal

CERTIFICATE OF CONFERENCE

I discussed this motion via email with counsel for Appellant the State
of Texas. Counsel for the State of Texas is not opposed to the requested relief.

/s/ Bryan P. Neal
Bryan P. Neal

Appellee State Fair of Texas’s Unopposed Motion
for Extension of Time to File Brief —Page 4
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.

Envelope ID: 108190820
Filing Code Description: Motion
Filing Description: Appellee State Fair of Texas???s Unopposed Motion
for Extension of Time to File Brief
Status as of 11/18/2025 3:17 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Joseph AIrrobali airrobali@tillotsonlaw.com 11/18/2025 3:12:04 PM SENT

Bryan Neal 788106 Bryan.Neal@hklaw.com 11/18/2025 3:12:04 PM SENT

James Harris 9065400 jim.harris@hklaw.com 11/18/2025 3:12:04 PM SENT

Melissa Juarez melissa.juarez@oag.texas.gov 11/18/2025 3:12:04 PM SENT

Kira Lytle klytle@tillotsonlaw.com 11/18/2025 3:12:04 PM SENT

Sherri Rodgers sherri.rodgers@hklaw.com 11/18/2025 3:12:04 PM SENT

Ernest Garcia ernest.garcia@oag.texas.gov 11/18/2025 3:12:04 PM SENT

Catherine Hughes catherine.hughes@oag.texas.gov 11/18/2025 3:12:04 PM SENT

Nathaniel Buchheit nbuchheit@tillotsonlaw.com 11/18/2025 3:12:04 PM SENT

Paul Pruneda paul.pruneda@oag.texas.gov 11/18/2025 3:12:04 PM SENT

Megan Coker mcoker@tillotsonlaw.com 11/18/2025 3:12:04 PM SENT

Anne Johnson ajohnson@tillotsonlaw.com 11/18/2025 3:12:04 PM SENT

TJP Service tillotsonjohnsonpatton@gmail.com 11/18/2025 3:12:04 PM SENT

Meridith Fischer Meridith.Fischer@oag.texas.gov 11/18/2025 3:12:04 PM SENT

Connor Ellington connor@tonymcdonald.com 11/18/2025 3:12:04 PM SENT

Connor Ellington connor@tonymcdonald.com 11/18/2025 3:12:04 PM SENT

Connor Ellington connor@tonymcdonald.com 11/18/2025 3:12:04 PM SENT

Steven Ogle Steven.Ogle@oag.texas.gov 11/18/2025 3:12:04 PM SENT

Tony McDonald Tony@tonymcdonald.com 11/18/2025 3:12:04 PM SENT

Jeffrey Tillotson 20039200 jtillotson@tillotsonlaw.com 11/18/2025 3:12:04 PM SENT

Holly Dudrick holly.dudrick@oag.texas.gov 11/18/2025 3:12:04 PM SENT

William Cole William.Cole@oag.texas.gov 11/18/2025 3:12:04 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.

Envelope ID: 108190820
Filing Code Description: Motion
Filing Description: Appellee State Fair of Texas???s Unopposed Motion
for Extension of Time to File Brief
Status as of 11/18/2025 3:17 PM CST

Case Contacts

William Cole William.Cole@oag.texas.gov 11/18/2025 3:12:04 PM SENT

William Peterson William.Peterson@oag.texas.gov 11/18/2025 3:12:04 PM SENT

Bryan Neal bryan.neal@hklaw.com 11/18/2025 3:12:04 PM SENT

Robert B.Smith Robert@Smith-Firm.com 11/18/2025 3:12:04 PM SENT

Canon ParkerHill canon.hill@oag.texas.gov 11/18/2025 3:12:04 PM SENT

Devlin Browne dbrowne@tillotsonlaw.com 11/18/2025 3:12:04 PM SENT

Dina W.McKenney dina.mckenney@hklaw.com 11/18/2025 3:12:04 PM SENT