Glenn Hegar, Comptroller of Public Accounts of the State of Texas and Ken Paxton, Attorney General of the State of Texas v. American Airlines, Inc.

Opinion

ACCEPTED 15-24-00113-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 4/16/2025 9:14 AM No. 15-24-00113-CV CHRISTOPHER A. PRINE CLERK In the Court of Appeals FILED IN for the Fifteenth District 15th COURT OF APPEALS AUSTIN, TEXAS Austin, Texas 4/16/2025 9:14:46 AM CHRISTOPHER A. PRINE Glenn Hegar, Comptroller of Public Accounts of the State Clerk of Texas, and Ken Paxton, Attorney General of the State of Texas, Appellants, V.

American Airlines, Inc., Appellee.

On Appeal from the 98th Judicial District Court, Travis County, Texas Cause Number D-1-GN-16-000621

Appellants’ Unopposed First Motion for Extension of Time to File Appellants’ Reply Brief

KEN PAXTON DEBORAH J. RAO Attorney General Assistant Attorney General State Bar No. 24131915 BRENT WEBSTER deborah.rao@oag.texas.gov First Assistant Attorney General RAY LANGENBERG Specially Deputized RALPH MOLINA Assistant Attorney General Deputy First Assistant Attorney State Bar No. 11911200 General ray.langenberg@cpa.texas.gov ALYSON “ALLY” THOMPSON AUSTIN KINGHORN Assistant Attorney General Deputy Attorney General for Civil State Bar No. 24143794 Litigation Office of the Attorney General Tax Litigation Division P.O. Box 12548 STEVEN ROBINSON Austin, Texas 78711 Division Chief, Tax Litigation Tel: 512-475-3503 Division Fax: 512-478-4013 Counsel for Appellants

MOTION TO EXTEND

1. Appellants ask the Court to grant an extension of fourteen (14)

days to file their reply brief, extending the due date from Monday,

April 28, 2025, to Monday, May 12, 2025.

2. This is Appellants’ first request for an extension of time to file

their reply brief.

3. Good cause exists for the Court to grant this extension.

4. Specifically, the undersigned counsel, Deborah J. Rao, will be

occupied with the following matters, among others: (1) assisting with

pretrial proceedings and dispositive motions for Cause No. D-1-GN-23-

002309 in Travis County District Court; (2) has a trial setting on April

28, 2025, with pretrial deadlines through April 2025, for Cause No. D-

1-GN-21-003065 in Travis County District Court; (3) has discovery

matters for Cause No. D-1-GN-24-003569 in Travis County District

Court; and (4) has discovery matters for Cause No. D-1-GN-24-003704

in Travis County District Court.

5. Additionally, the undersigned counsel, along with her office’s

staff, have personal commitments related to the Texas Office of the

Attorney General’s closure on April 18, 2025.

3

6. Due to these reasons and other time constraints, Appellants

require additional time to submit their Appellants’ reply brief.

7. This extension is not being sought for purposes of delay but so

that justice may be done.

8. The undersigned counsel conferred with Mr. Richard B. Phillips,

Jr., counsel for Appellee, on April 15, 2025. On April 15, 2025, Mr.

Phillips indicated that Appellee is unopposed to Appellants’ request for

a 14-day extension of the due date for Appellants’ reply brief.

9. All facts recited 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.

PRAYER

Appellants request that this motion be granted, extending the

time for filing Appellants’ reply brief to May 12, 2025.

4

Respectfully submitted.

KEN PAXTON /s/ Deborah J. Rao Attorney General DEBORAH J. RAO Assistant Attorney General State Bar No. 24131915 BRENT WEBSTER Deborah.Rao@oag.texas.gov First Assistant Attorney General RAY LANGENBERG Specially Deputized Assistant Attorney General RALPH MOLINA State Bar No. 11911200 Deputy First Assistant Attorney ray.langenberg@cpa.texas.gov General ALYSON “ALLY” THOMPSON Assistant Attorney General AUSTIN KINGHORN State Bar No. 24143794 Deputy Attorney General for Office of the Attorney General Civil Litigation Tax Litigation Division P. O. Box 12548, Capitol Station Austin, Texas 78711-2548 STEVEN ROBINSON T: (512) 475-3503 Chief, Tax Litigation Division F: (512) 478-4013 Counsel for Appellants

5

CERTIFICATE OF CONFERENCE

Deborah Rao conferred with Richard B. Phillips, Jr., counsel for Appellee, by email on April 15, 2025. Appellee is unopposed to this motion.

/s/ Deborah J. Rao Deborah J. Rao Assistant Attorney General Tax Litigation Division

6

CERTIFICATE OF SERVICE I certify that on April 16, 2025, a copy of the foregoing pleading was served on all parties or attorneys of record via the service methods listed below.

Via Electronic Service and/or email:

Mary A. McNulty Mary.McNulty@hklaw.com Leonora Meyercord Lee.Meyercord@hklaw.com Richard B. Phillips, Jr. Rich.Phillips@hklaw.com Holland & Knight LLP One Arts Plaza 1722 Routh Street, Suite 1500 Dallas, Texas 75201 214-964-9500 Fax: 214-964-9501

ATTORNEYS FOR APPELLEE

/s/ Deborah J. Rao Deborah J. Rao Assistant Attorney General Tax Litigation Division

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.

David Neuman on behalf of Deborah Rao Bar No. 24131915 david.neuman@oag.texas.gov Envelope ID: 99725719 Filing Code Description: Motion Filing Description: Appellants Unopposed First Motion for Extention of Time to File Appellants Reply Brief Status as of 4/16/2025 9:24 AM CST

Associated Case Party: AMERICAN AIRLINES, INC

Name BarNumber Email TimestampSubmitted Status

Richard Phillips 24032833 Rich.Phillips@hklaw.com 4/16/2025 9:14:46 AM SENT

Leonora Meyercord 24074711 Lee.Meyercord@hklaw.com 4/16/2025 9:14:46 AM SENT

Mary McNulty 13839680 Mary.McNulty@hklaw.com 4/16/2025 9:14:46 AM SENT

Meghan McCaig meghan.mccaig@hklaw.com 4/16/2025 9:14:46 AM SENT

Associated Case Party: GLENN HEGAR COMPTROLLER

Name BarNumber Email TimestampSubmitted Status

Ray Langenberg 11911200 ray.langenberg@cpa.texas.gov 4/16/2025 9:14:46 AM SENT

Kyle PierceCounce kyle.counce@oag.texas.gov 4/16/2025 9:14:46 AM SENT

Alyson “Ally” Thompson ally.thompson@oag.texas.gov 4/16/2025 9:14:46 AM SENT

Deborah Rao Deborah.Rao@oag.texas.gov 4/16/2025 9:14:46 AM SENT