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
10/17/2025 3:38 PM
Cause No. 15-25-00022-CV CHRISTOPHER A. PRINE
CLERK
In the Court of Appeals
FILED IN
For the Fifteenth District of Texas
15th COURT OF APPEALS
AUSTIN, TEXAS
City of Coppell, Texas, et al., 10/17/2025 3:38:13 PM
Appellants/Cross-Appellees,
CHRISTOPHER A. PRINE
Clerk
v.
Kelly Hancock, in His Official Capacity as Acting
Comptroller of Public Accounts of the State of
Texas,
Appellee/Cross-Appellant.
Appeal from the 201st Judicial District Court of Travis County, Texas
Hon. Karin Crump, Presiding
All Parties’ Joint Motion
to Extend Time to File Response Briefs

James B. Harris Cindy Olson Bourland
State Bar No. 09065400 State Bar No. 00790343
james.harris@hklaw.com bourland@bourlandlaw.com
Stephen F. Fink Bourland Law Firm, P.C.
State Bar No. 07013500 P.O. Box 546
stephen.fink@hklaw.com Round Rock, Texas 78680
Richard B. Phillips, Jr.
State Bar No. 24032833 Bryan J. Dotson
rich.phillips@hklaw.com State Bar No. 24072769
Reed C. Randel bryan.dotson@chamberlainlaw.com
State Bar No. 24075780 Chamberlain, Hrdicka, White,
reed.randel@hklaw.com Williams & Aughtry, P.C.
Holland & Knight LLP 112 East Pecan Street, Ste. 1450
1722 Routh Street, Suite 1500 San Antonio, Texas 78205
Dallas, Texas 75201
Phone: (214) 964-9500 Counsel for Appellee City of
Round Rock, Texas
Counsel for Cross-
Appellees the Coppell
Parties
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

STEVEN ROBINSON
Division Chief, Tax Litigation
Division

KYLE PIERCE COUNCE
State Bar No. 24082862
kyle.counce@oag.texas.gov
Assistant Attorney General
Tax Litigation Division
P. O. Box 12548
Austin, Texas 78711-2548
Phone: (512) 463-3112

Counsel for Appellee Kelly
Hancock, in His Official
Capacity as Acting
Comptroller of Public
Accounts of the State of
Texas

Joint Motion to Extend Time to File Response Briefs—
Page 2
To the Honorable Court of Appeals:
1. Under Texas Rules of Appellate Procedure 2, 10.5(b), and 38.6(d), Appellee

City of Round Rock, Texas (“Round Rock”), Appellee Kelly Hancock, in His

Official Capacity as Acting Comptroller of Public Accounts of the State of Texas

(“Comptroller”), and Cross-Appellees City Coppell, Texas, City of Humble, Texas,

City of DeSoto, Texas, City of Carrollton, Texas, and City of Farmers Branch, Texas

(the “Coppell Parties”) respectfully request a 30-day extension on the due dates for

their response 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. Round Rock’s response brief as appellee, the Comptroller’s

response brief as appellee, and the Coppell Parties’ response brief as cross-appellees

are all currently due on Monday, October 27, 2025. The requested extensions would

make the briefs due on Wednesday, November 26, 2025. This is the first request for

extension of the due dates for these briefs.

3. No party opposes any other party’s request for an extension of time.

4. Round Rock requests this extension because its counsel has been and will be

occupied with other case matters and travel that will prevent them from filing the

brief by the current due date. Among other matters, lead counsel Cindy Olson

Joint Motion to Extend Time to File Response Briefs—Page 1
Bourland will be out of state from October 24 to October 31, 2025, and also needs

additional time to thoroughly research and address the issues presented by this

appeal.

5. The Comptroller requests this extension because their lead counsel, Kyle

Pierce Counce, is occupied with other case matters that will prevent them from filing

the brief by the current due date. Among other matters, lead counsel has been

occupied with the following:

(a) preparing for and presenting oral argument on October 30, 2025, in No. 15-
24-00113-CV, Hancock v. American Airlines, Inc., pending in this Court;

(b) assisting in preparation for oral argument on October 30, 2025 (oral
argument canceled on October 16, 2025), in No. 15-24-00111-CV, Hancock
v. Championx, LLC;

(c) preparing for a Plea to the Jurisdiction hearing held on October 15, 2025 in
No. D-1-GN-25-000438, City of Lancaster v. Hegar, et al., pending in the
345th Judicial District Court of Travis County, Texas; and

(d) mediating Cause No. 3:23-cv-00810, Stinson v. Jones, et al., in the United
States District Court for the Northern District of Texas.

6. The Coppell Parties request this extension primarily because their lead

counsel, James B. Harris, will be out of the country on a long-planned 50th wedding

anniversary trip to Africa from October 9 through October 27. The trip covers most

of the time to prepare the response brief and Mr. Harris will still be out of the country

on the current due date. Additionally, the Coppell Parties other counsel has been

Joint Motion to Extend Time to File Response Briefs—Page 2
and will be occupied with other matters that will prevent them from filing the brief

by the current due date. Among other matters, counsel has been occupied with the

following:

(a) preparing the appellee’s response brief due on October 8, 2025, in Miller v.
Dunn, et al., No. 05-25-00768-CV, pending in the Court of Appeals for the
Fifth District of Texas;

(b) preparing the appellants’ opening brief in Cockerill, et al. v. Corteva, et al..,
No. 25-2204 and No. 25-2312, pending in the United States Court of
Appeals for the Third Circuit;

(c) preparing the petition for review due on October 29, 2025, in 25-0863,
Southern Cornerstone, Inc. v. Crown Colony Improvement Association, Inc.,
pending the Supreme Court of Texas; and

(d) preparing for and presenting oral argument on October 30, 2025, in No. 15-
24-00113-CV, Hancock v. American Airlines, Inc., pending in this Court.

Therefore, Round Rock, the Comptroller, and the Coppell Parties request that

the Court extend the deadline for their response briefs to Wednesday, November 26,

2025.

Joint Motion to Extend Time to File Response Briefs—Page 3
Dated: October 17, 2025

Respectfully submitted,

Holland & Knight LLP Bourland Law Firm, P.C.
P.O. Box 546
By: /s/ Richard B. Phillips, Jr. Round Rock, Texas 78680
James B. Harris
State Bar No. 09065400 By: /s/ Cindy Olson Bourland
james.harris@hklaw.com Cindy Olson Bourland
Stephen F. Fink State Bar No. 00790343
State Bar No. 07013500 bourland@bourlandlaw.com
stephen.fink@hklaw.com
Richard B. Phillips, Jr. Chamberlain, Hrdicka,
State Bar No. 24032833 White, Williams &
rich.phillips@hklaw.com Aughtry, P.C.
Reed C. Randel Bryan J. Dotson
State Bar No. 24075780 State Bar No. 24072769
reed.randel@hklaw.com bryan.dotson@chamberlainlaw.com
1722 Routh Street, Suite 1500 112 East Pecan Street, Ste. 1450
Dallas, Texas 75201 San Antonio, Texas 78205
Phone: (214) 964-9500
Counsel for The City of
Counsel for The Coppell Round Rock, Texas
Parties

Joint Motion to Extend Time to File Response Briefs—Page 4
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
STEVEN ROBINSON
Division Chief, Tax Litigation Division
/s/ Kyle Pierce Counce
KYLE PIERCE COUNCE
State Bar No. 24082862
kyle.counce@oag.texas.gov
Assistant Attorney General
Tax Litigation Division
P. O. Box 12548
Austin, Texas 78711-2548
T: (512) 463-3112
F: (512) 478-4013

COUNSEL FOR Kelly Hancock,
in His Official Capacity as
Acting Comptroller of
Public Accounts of the
State of Texas

Joint Motion to Extend Time to File Response Briefs—Page 5
Certificate of Conference

This is a joint request by all parties to this appeal and all parties have consented
to the extensions requested by the other parties.

/s/ Richard B. Phillips, Jr.
Richard B. Phillips, Jr.

Joint Motion to Extend Time to File Response Briefs—Page 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.

Richard Phillips on behalf of Richard Phillips Jr.
Bar No. 24032833
Rich.Phillips@hklaw.com
Envelope ID: 106998333
Filing Code Description: Motion
Filing Description: Joint Motion for Extension of Time to File Response
Briefs
Status as of 10/17/2025 3:44 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Richard Phillips 24032833 Rich.Phillips@hklaw.com 10/17/2025 3:38:13 PM SENT

Bryan Dotson 24072769 bryan.dotson@chamberlainlaw.com 10/17/2025 3:38:13 PM SENT

Ray Langenberg 11911200 ray.langenberg@cpa.texas.gov 10/17/2025 3:38:13 PM SENT

Reed Randel 24075780 Reed.Randel@hklaw.com 10/17/2025 3:38:13 PM SENT

Stephen Fink 7013500 Stephen.Fink@hklaw.com 10/17/2025 3:38:13 PM SENT

James Harris 9065400 jim.harris@hklaw.com 10/17/2025 3:38:13 PM SENT

Kyle Counce 24082862 Kyle.Counce@oag.texas.gov 10/17/2025 3:38:13 PM SENT

Cynthia Bourland 790343 bourland@bourlandlaw.com 10/17/2025 3:38:13 PM SENT

Brandon L.King brandon.king@hklaw.com 10/17/2025 3:38:13 PM SENT