Home/Court of Appeals of Texas/Arnulfo Cortez, Jr.; Homero R. Balderas, Brian D. Nipper, Mark F. Van Rosendael and Bryan K. Hugghins v. Texas Commission on Law Enforcement; Gregory Stevens in His Capacity as Executive Director of the Texas Commission on Law Enforcement; And John Beauchamp, in His Official Capacity as Counsel for Texas Commission on Law Enforcement; And T.J. Vineyard, in His Official Capacity as Major for the Texas Commission on Law Enforcement

Arnulfo Cortez, Jr.; Homero R. Balderas, Brian D. Nipper, Mark F. Van Rosendael and Bryan K. Hugghins v. Texas Commission on Law Enforcement; Gregory Stevens in His Capacity as Executive Director of the Texas Commission on Law Enforcement; And John Beauchamp, in His Official Capacity as Counsel for Texas Commission on Law Enforcement; And T.J. Vineyard, in His Official Capacity as Major for the Texas Commission on Law Enforcement

Court of Appeals of Texas·Decided February 26, 2025·No. 15-24-00116-CV·Published

Opinion

ACCEPTED

15-24-00116-CV

FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS

2/26/2025 3:58 PM

No. 15-24-00116-CV CHRISTOPHER A. PRINE CLERK

IN THE FIFTEENTH COURT OF APPEALS FILED IN 15th COURT OF APPEALS

AUSTIN, TEXAS AUSTIN, TEXAS 2/26/2025 3:58:26 PM

CHRISTOPHER A. PRINE

Clerk

ARNULFO CORTEZ, JR., HOMERO R. BALDERAS, BRIAN D. NIPPER, MARK F. VAN ROSENDAEL, AND BRYAN K.

HUGGHINS

Appellants,

V.

TEXAS COMMISSION ON LAW ENFORCEMENT, GREGORY STEVENS IN HIS CAPACITY AS THE EXECUTIVE DIRECTOR OF THE TEXAS COMMISSION ON LAW ENFORCEMENT, JOHN BEAUCHAMP IN HIS OFFICIAL CAPACITY AS COUNSEL FOR TEXAS COMMISSION ON LAW ENFORCEMENT AND T.J.

VINEYARD, IN HIS OFFICIAL CAPACITY AS MAJOR FOR TEXAS COMMISSION ON LAW ENFORCEMENT Appellees.

On Appeal from Cause No. D-1-GN-24-002797 in the 455th Judicial District Court, Travis County, Texas, Hon. Daniella Deseta Lyttle

MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF

HYDE KELLEY LLP GEORGE E. HYDE 2806 Flintrock Trace, Suite A104 Texas Bar No. 45006157 Austin, Texas 78738 ghyde@txlocalgovlaw.com Telephone: (512) 686-0700 MATTHEW L. WESTON Facsimile: (866) 929-1641 Texas Bar No. 24037698 mweston@txlocalgovlaw.com Texas State Bar No. 24113617

TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

Appellants Arnulfo Cortez et al. (“Appellants”) respectfully move to extend the time to file the Appellant’s Reply Brief (“Reply Brief”) pursuant to Tex. R. App. P. 10.5(b). In support of its Motion, Appellants will show the Court as follows:

1. The current deadline for filing the Reply Brief is Tuesday, March 4, 2025.

2. Appellants seek a 14-day extension to file the Reply Brief, moving the deadline to March 18, 2025.

3. Appellants have not previously requested or been granted extension of time to file the Reply Brief.

4. Counsel for Appellants seek this extension due to the following competing due dates and obligations in other pending matters:

a. Sanchez v. Medina County and Jonathan Bates Nunmaker, United States District Court, Western District of Texas, Cause No. 5:25-cv-00109

i. Answer due February 27, 2025 b. Legacy Hutto, LLC v. City of Hutto, 395th Judicial District, Williamson County, Cause No. 20-0863-C395 i. Disclosure due Responses February 28, 2025 ii. Jurisdictional Discovery Responses due March 6, 2025

c. In Re Shana L. Robinson and Robinson-Barrett Insurance Services, LLC, Texas Fourth Court of Appeals, Cause No. 04-25-

00058-CV

i. Amended Petition for Writ of Mandamus due Monday March 3, 2025

d. Roznovak v. Hutto Economic Development Corporation, Williamson County Court at Law Number 5, Cause No. 24-139-

CC5

i. Amended Motion for Summary Judgment due Monday March 3, 2025

ii. Hearing on Motion to Quash March 6, 2025 e. City of Cibolo v. Zunker, Texas Fourth Court of Appeals, Cause No. 04-25-00114-CV

i. Docketing Statement due March 3, 2025 5. This extension is not sought for purposes of delay, but so that justice may be done.

PRAYER

For the foregoing reasons, Appellants request the Court grant the motion to extend time for filing its Appellants’ Reply Brief by fourteen days, until March 18, 2025.

Dated: February 26, 2025 Respectfully submitted,

HYDE KELLEY LLP

2806 Flintrock Trace, Suite A104 Austin, Texas 78738

Telephone: (512) 686-0700 Facsimile: (866) 929-1641

/s/ George E. Hyde

GEORGE E. HYDE

Texas State Bar No. 45006157 ghyde@txlocalgovlaw.com

MATTHEW L. WESTON

Texas State Bar No. 24037698 mweston@txlocalgovlaw.com

ATTORNEYS FOR APPELLANTS

CERTIFICATE OF CONFERENCE Pursuant to Tex. R. App. P. 10.1(a)(5), I certify that I have conferred with opposing counsel in this case regarding this motion. Counsel for Appellees is unopposed to this motion.

/s/ George E. Hyde

GEORGE E. HYDE

CERTIFICATE OF SERVICE

I, the undersigned attorney, hereby certify that on February 26, 2025, a true and correct copy of the forgoing document was served in accordance with the Texas Rules of Appellate Procedure upon the counsel of record in this cause via electronic service and email. Lauren McGee Lauren.mcgee@oag.texas.gov

Assistant Attorney General Administrative Law Division Office of the Attorney General of Texas P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Telephone: (512) 475-3203

ATTORNEYS FOR APPELLEES

/s/ George E. Hyde

GEORGE E. HYDE

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.

Lauren Fogerty on behalf of George Hyde Bar No. 45006157 lfogerty@txlocalgovlaw.com Envelope ID: 97836448 Filing Code Description: Motion Filing Description: Motion for Extension of Time to File Reply Brief Status as of 2/26/2025 4:02 PM CST

Associated Case Party: TEXAS COMMISSION ON LAW ENFORCEMENT Name BarNumber Email TimestampSubmitted Status Jennifer Foster Jennifer.Foster@oag.texas.gov 2/26/2025 3:58:26 PM SENT

Associated Case Party: City of Cibolo Name BarNumber Email TimestampSubmitted Status Victoria Wilhelm vwilhelm@txlocalgovlaw.com 2/26/2025 3:58:26 PM SENT Lauren Fogerty lfogerty@txlocalgovlaw.com 2/26/2025 3:58:26 PM SENT

Case Contacts Name BarNumber Email TimestampSubmitted Status George Hyde 45006157 ghyde@txlocalgovlaw.com 2/26/2025 3:58:26 PM SENT Matthew Weston 24037698 mweston@txlocalgovlaw.com 2/26/2025 3:58:26 PM SENT Lauren McGee 24128835 Lauren.mcgee@oag.texas.gov 2/26/2025 3:58:26 PM SENT

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Arnulfo Cortez, Jr.; Homero R. Balderas, Brian D. Nipper, Mark F. Van Rosendael and Bryan K. Hugghins v. Texas Commission on Law Enforcement; Gregory Stevens in His Capacity as Executive Director of the Texas Commission on Law Enforcement; And John Beauchamp, in His Official Capacity as Counsel for Texas Commission on Law Enforcement; And T.J. Vineyard, in His Official Capacity as Major for the Texas Commission on Law Enforcement, (Tex. Ct. App. 2025).

Arnulfo Cortez, Jr.; Homero R. Balderas, Brian D. Nipper, Mark F. Van Rosendael and Bryan K. Hugghins v. Texas Commission on Law Enforcement; Gregory Stevens in His Capacity as Executive Director of the Texas Commission on Law Enforcement; And John Beauchamp, in His Official Capacity as Counsel for Texas Commission on Law Enforcement; And T.J. Vineyard, in His Official Capacity as Major for the Texas Commission on Law Enforcement (Arnulfo Cortez, Jr.; Homero R. Balderas, Brian D. Nipper, Mark F. Van Rosendael and Bryan K. Hugghins v. Texas Commission on Law Enforcement; Gregory Stevens in His Capacity as Executive Director of the Texas Commission on Law Enforcement; And John Beauchamp, in His Official Capacity as Counsel for Texas Commission on Law Enforcement; And T.J. Vineyard, in His Official Capacity as Major for the Texas Commission on Law Enforcement) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.