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
12/22/2025 12:21 PM
No. 15-25-00086-CV CHRISTOPHER A. PRINE
CLERK
IN THE COURT OF APPEALS FILED IN
FOR THE FIFTEENTH DISTRICT OF TEXAS AUSTIN, TEXAS
15th COURT OF APPEALS

AT AUSTIN, TEXAS 12/22/2025 12:21:09 PM
____________________________________________________________
CHRISTOPHER A. PRINE
Clerk
CITY OF GRAND PRAIRIE, ET AL.,
Appellants – Plaintiffs

CITY OF BROWNSVILE, CITY OF ANNA, AND CITY OF BONHAM
Appellants – Intervenor Plaintiffs

2020 LONG TAIL TRAIL INVESTMENTS, LLC
Appellants – Intervenor Defendant

v.

THE STATE OF TEXAS, ATTORNEY GENERAL KENNETH PAXTON, IN HIS OFFICIAL
CAPACITY, TEXAS COMPTROLLER OF PUBLIC CAPACITY, TEXAS COMPROLLER OF
PUBLIC ACCOUNTS GLENN HAGAR, IN HIS OFFICIAL CAPACITY, AND THE OFFICE
OF THE TEXAS COMPROLLER OF PUBLIC ACCOUNTS
Appellees – Defendants
____________________________________________________________

APPELLANTS – INTERVENOR PLAINTIFFS CITY OF ANNA and CITY
OF BONHAM’s SECOND UNOPPOSED MOTION
FOR EXTENSION OF TIME TO FILE BRIEF
____________________________________________________________

Pursuant to Rule 10.5(b) of the Texas Rules of Appellate Procedure,

Appellants – Intervenor Plaintiffs, City of Anna (“Anna”) and City of Bonham

- APPELLANTS – INTERVENOR PLAINTIFFS SECOND UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE BRIEF - Page 1 of 5
(“Bonham”)(collectively, “Movants”) respectfully requests an approximately

two week extension of time to file their reply briefs.1

1. Movants filed a notice of appeal on May 8, 2025.

2. Movants’ principal brief was filed on August 15, 2025.

3. Appellee’s response brief was due Monday, September 15, 2025

and requested a 30-day extension until October 15, 2025 which was granted.

4. Appellees filed a second unopposed motion for extension of time

for an additional 16 days, which was granted and extended their response

deadline to October 31, 2025.

5. Appellees filed a third unopposed motion for extension of time for

an additional 14 days extending their deadline to November 14, 2025.

6. Appellant Cities (the parties other than Anna and Bonham who

constitute plaintiffs in the original suit) filed an unopposed extension of time

for their reply brief on December 1, 2025, which was granted and extended

their reply brief deadline to December 29, 2025. Movants were granted a

similar extension after their unopposed motion was filed December 4, 2025.

1 Although Anna and Bonham are represented by the same attorneys in this cause, they are independent

parties operating under separate pleadings. Due to differences between them, they may submit separate
briefs as this appeal progresses. That said, they are joined in this request for extension of their deadlines
to file reply briefs.

- APPELLANTS – INTERVENOR PLAINTIFFS SECOND UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE BRIEF - Page 2 of 5
7. Appellant Cities filed a second unopposed motion for extension

of time for their reply brief on December 18, 2025, which was granted and

extended their deadline to January 8, 2026.

8. Movants current deadline to file a reply brief is December 29,

2025.

9. The Movants seek additional time to file their respective briefs,

in part due to the complexity of the issues and the unexpected events which

have disrupted timing matters for the other appellants. In addition, the

requested extension of the Movants’ deadlines will synchronize them with

other appellants: it should enhance judicial efficiency, reduce chances for

confusion, and will cause no additional delays in final resolution of the case.

10. The Court has authority under Texas Rule of Appellate

Procedure 38.6(d) to extend the time to file a brief.

11. Appellees are unopposed to the relief requested herein.

12. One extension was previously requested and granted to extend

the time to file the Movants’ reply brief. It is not anticipated that the Movants

will seek any further extensions of this deadline.

WHEREFORE, Appellants – Intervenor Plaintiffs, Cities of Anna and

Bonham, pray that the Court grant this motion and likewise extend the time

to file their reply briefs to the same deadline as provided to other parties,

- APPELLANTS – INTERVENOR PLAINTIFFS SECOND UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE BRIEF - Page 3 of 5
that being January 8, 2026.

Respectfully submitted,

/s/David Overcash
David Overcash
State Bar No. 24075516
david.overcash@wtmlaw.net
Clark McCoy
State Bar No. 90001803
cmccoy@wtmlaw.net

WOLFE, TIDWELL & MCCOY, LLP
2591 N. Dallas Parkway, Suite 300
Frisco, Texas 75034
972.712.3530 telephone
972.712.3540 facsimile

ATTORNEYS FOR
CITY OF ANNA, TEXAS and
CITY OF BONHAM, TEXAS

- APPELLANTS – INTERVENOR PLAINTIFFS SECOND UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE BRIEF - Page 4 of 5
CERTIFICATE OF CONFERENCE

On or before December 22, 2025, counsel for the Movants participated
in conference with counsel for appellees and the Appellant Cities regarding
the merits of this motion, and all indicated that they are unopposed to the
requested extension.
/s/ David Overcash

CERTIFICATE OF SERVICE
This is to 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 December
22, 2025.

/s/ David Overcash

- APPELLANTS – INTERVENOR PLAINTIFFS SECOND UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE BRIEF - Page 5 of 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.

Crystal Adams on behalf of David Overcash
Bar No. 24075516
cadams@wtmlaw.net
Envelope ID: 109364471
Filing Code Description: Motion
Filing Description: Appellants-Intervenor Plaintiffs City of Anna and City of
Bonham's Second Unopposed Motion for Extension of Time to File Brief
Status as of 12/22/2025 12:27 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Jennifer Holt jennifer.holt@oag.texas.gov 12/22/2025 12:21:09 PM SENT

Allison Collins 24127467 Acollins@fosterswift.com 12/22/2025 12:21:09 PM SENT

Lena Chaisson-Munoz lena.munoz@brownsvilletx.gov 12/22/2025 12:21:09 PM SENT

Cole Wilson Cole.Wilson@oag.texas.gov 12/22/2025 12:21:09 PM SENT

Tristan AGarza tristan.garza@oag.texas.gov 12/22/2025 12:21:09 PM SENT

Lynn Saarinen lynn.saarinen@oag.texas.gov 12/22/2025 12:21:09 PM SENT

Will S.Trevino will.trevino@brownsvilletx.gov 12/22/2025 12:21:09 PM SENT

Sherry Brown sherry@txmunicipallaw.com 12/22/2025 12:21:09 PM SENT

Andy Messer andy@txmunicipallaw.com 12/22/2025 12:21:09 PM SENT

Brad Bullock brad@txmunicipallaw.com 12/22/2025 12:21:09 PM SENT

Timothy Dunn Taddunn@txmunicipallaw.com 12/22/2025 12:21:09 PM SENT

Todd Disher todd@lehotskykeller.com 12/22/2025 12:21:09 PM SENT

William Thompson will@lkcfirm.com 12/22/2025 12:21:09 PM SENT

Cole Wilson cole.wilson@oag.texas.gov 12/22/2025 12:21:09 PM SENT

Guillermo Trevino will.trevino@brownsvilletx.gov 12/22/2025 12:21:09 PM SENT

Lena Chaisson-Munoz lena.munoz@brownsvilletx.gov 12/22/2025 12:21:09 PM SENT

George Hyde ghyde@txlocalgovlaw.com 12/22/2025 12:21:09 PM SENT

Matthew Weston mweston@txlocalgovlaw.com 12/22/2025 12:21:09 PM SENT

David Overcash david.overcash@wtmlaw.net 12/22/2025 12:21:09 PM SENT

Clark McCoy cmccoy@wtmlaw.net 12/22/2025 12:21:09 PM SENT