2020 Long Tail Trail Investments, LLC v. State of Texas, Attorney General Kenneth Paxton (In His Official Capacity), Acting Texas Comptroller of Public Accounts Kelly Hancock (In His Official Capacity), and the Office of the Texas Comptroller of Public Accounts

ACCEPTED
15-25-00086-Cv
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
8/26/2025 3:01 PM
No. 15-25-00086-CV CHRISTOPHER A. PRINE
CLERK
FILED IN
In the Court of Appeals 15th AUSTIN,
COURT OF APPEALS
TEXAS
for the Fifteenth Judicial District
8/26/2025 3:01:04 PM
____________________________ CHRISTOPHER A. PRINE
Clerk

2020 LONG TAIL TRAIL INVESTMENTS, LLC, ET AL.,
Appellants,
v.
STATE OF TEXAS, ET AL.,
Appellees.
______________________________

On Appeal from the
261st Judicial District Court, Travis County
Cause No. D-1-GN-23-007785
______________________________

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
_____________________________

TO THE HONORABLE COURT OF APPEALS:

Pursuant to Texas Rules of Appellate Procedure 10.5(B) and 38.6,

Appellees State of Texas, Attorney General Kenneth Paxton (in his

official capacity), the Acting Texas Comptroller of Public Accounts Kelly

Hancock (in his official capacity), and the Office of the Texas Comptroller

of Public Accounts file this Unopposed Motion for Extension of Time to

File Brief, and would show the Court the following:

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1. Appellees response brief is due on Monday, September 15, 2025.

2. Appellees request a 30-day extension of time to file their response

brief until, Wednesday, October 15, 2025.

3. Lead Counsel for the Appellees, Mr. Cole P. Wilson, is on

paternity leave beginning August 21st, through mid-October, 2025, and

will be unable to prepare Appellees’ Response brief.

4. Appellees’ Additional Counsel, Ms. Lynn E. Saarinen, has other

matters demanding her time and attention; specifically:

4.1. Counsel must prepare for trial that is currently set in Harris

County, Texas for September 15th, 2025, if a continuance request

is not granted.

4.2. Additionally, Counsel has pre-approved leave during the last

week in August, and first week of September.

4.3. Finally, Counsel has several other previously scheduled

filings and briefings due in both federal and state court, including

the Texas Supreme Court, throughout September and October

2025.

5. This is Appellee’s first request for an extension of time.

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6. The requested extension is reasonable and necessary to allow

Appellees adequate time to prepare their response brief. This request is

not made for delay but only so that justice may be done.

7. Appellants do not oppose this motion.

8. Appellees request that this Court grant an extension of time for

30 days until October 15th, 2025, to file their response to Appellants’

opening briefs.

Wherefore, for the above reasons, Appellees State of Texas,

Attorney General Kenneth Paxton (in his official capacity), the Acting

Texas Comptroller of Public Accounts Kelly Hancock (in his official

capacity), and the Office of the Texas Comptroller of Public Accounts

respectfully request that the Court extend the time for filing their

response brief from September 15th, 2025, to October 15th, 2025.

Dated: August 26, 2025 Respectfully submitted,

Ken Paxton Austin Kinghorn
Attorney General of Texas Deputy Attorney General for Civil
Litigation
Brent Webster
First Assistant Attorney General Kimberly Gdula
Chief for General Litigation
Ralph Molina Division
Deputy First Assistant Attorney
General
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Cole P. Wilson
Assistant Attorney General
Texas State Bar No. 24122856
Cole.Wilson@oag.texas.gov

/s/ Lynn E. Saarinen
Lynn E. Saarinen
Assistant Attorney General
Texas State Bar No. 17498900
Lynn.Saarinen@oag.texas.gov

Office of the Attorney General
General Litigation Division
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
737-224-4634|Fax: 512-320-0667

Counsel for Appellees

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CERTIFICATE OF CONFERENCE

I hereby certify that on August 19, 2025, Counsel conferred by email

with Appellant’s Counsel, regarding this motion, and Appellant’s

Counsel is unopposed.

/s/Lynn E. Saarinen
Lynn E. Saarinen

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing

instrument has been sent via electronic service to all attorneys of record,

in compliance with Rule 6.3 of the Texas Rules of Appellate Procedure,

on August 26, 2025.

/s/Lynn E. Saarinen
Lynn E. Saarinen

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.

Raymond Abarca on behalf of Lynn Saarinen
Bar No. 17498900
raymond.abarca@oag.texas.gov
Envelope ID: 104870227
Filing Code Description: Motion
Filing Description: 20250826_Appellees Unopposed Motion for Extension
of Time Final
Status as of 8/26/2025 3:56 PM CST

Associated Case Party: City of Brownsville, Texas

Name BarNumber Email TimestampSubmitted Status

Lena Chaisson-Munoz lena.munoz@brownsvilletx.gov 8/26/2025 3:01:04 PM SENT

Will S.Trevino will.trevino@brownsvilletx.gov 8/26/2025 3:01:04 PM SENT

Associated Case Party: Attorney General Kenneth Paxton (in his Official Capacity

Name BarNumber Email TimestampSubmitted Status

Raymond Abarca Raymond.Abarca@oag.texas.gov 8/26/2025 3:01:04 PM SENT

Cole Wilson Cole.Wilson@oag.texas.gov 8/26/2025 3:01:04 PM SENT

Lynn Saarinen lynn.saarinen@oag.texas.gov 8/26/2025 3:01:04 PM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Sherry Brown sherry@txmunicipallaw.com 8/26/2025 3:01:04 PM SENT

Andy Messer andy@txmunicipallaw.com 8/26/2025 3:01:04 PM SENT

Brad Bullock brad@txmunicipallaw.com 8/26/2025 3:01:04 PM SENT

Timothy Dunn Taddunn@txmunicipallaw.com 8/26/2025 3:01:04 PM SENT

Todd Disher todd@lehotskykeller.com 8/26/2025 3:01:04 PM SENT

William Thompson will@lkcfirm.com 8/26/2025 3:01:04 PM SENT

Cole Wilson cole.wilson@oag.texas.gov 8/26/2025 3:01:04 PM SENT

Guillermo Trevino will.trevino@brownsvilletx.gov 8/26/2025 3:01:04 PM SENT

Lena Chaisson-Munoz lena.munoz@brownsvilletx.gov 8/26/2025 3:01:04 PM SENT

George Hyde ghyde@txlocalgovlaw.com 8/26/2025 3:01:04 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.

Raymond Abarca on behalf of Lynn Saarinen
Bar No. 17498900
raymond.abarca@oag.texas.gov
Envelope ID: 104870227
Filing Code Description: Motion
Filing Description: 20250826_Appellees Unopposed Motion for Extension
of Time Final
Status as of 8/26/2025 3:56 PM CST

Case Contacts

George Hyde ghyde@txlocalgovlaw.com 8/26/2025 3:01:04 PM SENT

Matthew Weston mweston@txlocalgovlaw.com 8/26/2025 3:01:04 PM SENT

David Overcash david.overcash@wtmlaw.net 8/26/2025 3:01:04 PM SENT

Clark McCoy cmccoy@wtmlaw.net 8/26/2025 3:01:04 PM SENT