Appraisal Review Board of the Harris County Appraisal District v. Texas Workforce Commission and Redona Hall

Opinion

ACCEPTED 15-25-00041-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 10/15/2025 1:00 PM No. 15-25-00041-CV CHRISTOPHER A. PRINE ____________________________________________________ CLERK FILED IN In the 15th COURT OF APPEALS AUSTIN, TEXAS Fifteenth Court of Appeals 10/15/2025 1:00:42 PM

Austin, Texas CHRISTOPHER A. PRINE Clerk ____________________________________________________

APPRAISAL REVIEW BOARD OF THE HARRIS COUNTY APPRAISAL DISTRICT, Appellant v.

TEXAS WORKFORCE COMMISSION and REDONA HALL, Appellees ____________________________________________________

Appellee Texas Workforce Commission’s Second Unopposed Motion for Extension of Time to File Response Brief ____________________________________________________

Appellee, Texas Workforce Commission (“TWC”) files this second unopposed motion

for extension of time to file its brief under Texas Rules of Appellate Procedure 10.5(b) and requests

that the time for filing its response brief in this matter be extended for thirty (30) days, from

November 3, 2025, to November 21, 2025, and in support shows as follows:

1. Respondent TWC’s Brief is due November 3, 2025.

2. Appellee TWC requests an additional 18 days to file its Brief, extending the deadline to

November 21, 2025.

3. This is TWC’s second request for an extension of time to file its brief.

Appellee TWC’s Second Unopposed Motion for Extension of Time to File Brief P a g e |1 4. Good cause exists to grant this extension. TWC requests more time to review the arguments

raised by Appellant and analyze the possible impact Appellant’s arguments would have on

the regarding TWC’s interpretation of the relevant statutory schemes and TWC’s policies.

Similarly, counsel for TWC would request more time to thoroughly address all arguments

raised by Appellant. TWC does not anticipate that any further requests for extension will

be needed.

5. This extension is not being sought for purposes of delay but rather to allow time to prepare

a thorough, succinct, and clear brief to be presented to the Court.

6. Counsel for TWC has conferred with counsel for Appellant, Ray Viada, and he is not

opposed to this motion.

7. All facts in this motion are within the personal knowledge of the undersigned counsel, so

no verification is necessary under Texas Rule of Appellate Procedure 10.2.

8. Wherefore, Appellee Texas Workforce Commission, requests that this motion be granted,

and that the time for filing its Brief be extended to November 21, 2025.

Appellee TWC’s Second Unopposed Motion for Extension of Time to File Brief P a g e |2 Respectfully submitted,

KEN PAXTON Attorney General

BRENT WEBSTER First Assistant Attorney General

RALPH MOLINA Deputy First Assistant Attorney General

AUSTIN KINGHORN Deputy Attorney General for Civil Litigation

STEVEN ROBINSON Chief, Tax Litigation Division

/s/ William Cohen William Cohen Assistant Attorney General Texas Bar No. 24082839 Will.Cohen@oag.texas.gov Tax Litigation Division Office of the Attorney General P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Tel: (512) 475-1743 Fax: (512) 478-4013

ATTORNEY FOR APPELLEE TEXAS WORKFORCE COMMISSION

Appellee TWC’s Second Unopposed Motion for Extension of Time to File Brief P a g e |3 CERTIFICATE OF CONFERENCE

On October 15, 2025, the undersigned counsel conferred with Ray Viada, counsel for Appellant, via email. Mr. Viada does not oppose this Motion.

/s/ William Cohen WILLIAM COHEN Assistant Attorney General

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoing document was served on counsel by e-service and/or e-mail on October 15, 2025, as indicated below:

Ray Viada Rayviada@viadastrayer.com VIADA & STRAYER Counsel for Appellant

Appellee TWC’s Second Unopposed Motion for Extension of Time to File Brief P a g e |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.

Lynee Pearson on behalf of William Cohen Bar No. 24082839 lynee.pearson@oag.texas.gov Envelope ID: 106874940 Filing Code Description: Motion Filing Description: 20251015 Appellees Second Unopposed Motion for Extension Status as of 10/15/2025 1:16 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Jennifer Holloway jholloway@viadastrayer.com 10/15/2025 1:00:42 PM SENT

Ramon G.Viada rayviada@viadastrayer.com 10/15/2025 1:00:42 PM SENT

Valerie Locher vlocher@viadastrayer.com 10/15/2025 1:00:42 PM SENT

Associated Case Party: Texas Workforce Commission

William Cohen 24082839 Will.Cohen@oag.texas.gov 10/15/2025 1:00:42 PM SENT