Home/Court of Appeals of Texas/Hays County, Texas, Ruben Becerra, Debbie Ingalsbe, Michelle Cohen, Morgan Hammer, and Walt Smith, in Their Official Capacities v. Leslie Carnes, Jim Camp, Cathy Ramsey, Gabrielle Moore, and Ken Paxton, Attorney General of Texas

Hays County, Texas, Ruben Becerra, Debbie Ingalsbe, Michelle Cohen, Morgan Hammer, and Walt Smith, in Their Official Capacities v. Leslie Carnes, Jim Camp, Cathy Ramsey, Gabrielle Moore, and Ken Paxton, Attorney General of Texas

Court of Appeals of Texas·Decided November 18, 2025·No. 15-25-00121-CV·Published

Opinion

ACCEPTED

15-25-00121-CV

FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 11/18/2025 5:59 PM

CHRISTOPHER A. PRINE

CLERK

THE OFFICE OF THE ATTORNEY GENERAL OF TEXAS FILED IN 15th COURT OF APPEALS

AUSTIN, TEXAS

November 18, 2025 11/18/2025 5:59:56 PM CHRISTOPHER A. PRINE

Clerk

Christopher A. Prine Via EFileTexas.gov Clerk of the Court William P. Clements Building 300 W. 15th Street, Suite 607 Austin, Texas 78701

RE: Court of Appeals Number: 15-25-00121-CV Trial Court Case Number: D-1-GN-25-002049

Style: Hays County, Texas, Ruben Becerra, Debbie Ingalsbe, Michelle Cohen, Morgan Hammer, and Walt Smith, in their official capacities v. Leslie Carnes, Jim Camp, Cathy Ramsey, Gabrielle Moore, and Ken Paxton, Attorney General of Texas

Dear Mr. Pine:

Ken Paxton, Attorney General of Texas, files this waiver of Response to the Appellants’ brief on the merits, which was filed on October 10th, 2025.

This appeal arises from a bond validation proceeding under the Expedited Declaratory Judgment Act (“EDJA”), Chapter 1205 of the Texas Government Code, filed in 2020. The Attorney General is a required party in such matters and has specific duties, including a duty to raise appropriate defenses, and a duty to help facilitate a just and expeditious resolution. See TEX. GOV’T CODE § 1205.063 (Duties of Attorney General).

Appellants state in their appellate brief that the Attorney General took no position on the Texas Open Meetings Act issue in the trial court. That is correct. However, if the notice of the meeting calling a bond election is not valid, then the bonds are not valid. In this regard, in his trial brief the Attorney General set forth issues the trial court should consider in determining whether the County complied with the Texas Open Meetings Act.

Because the remaining issue with Appellants, the SH-45 project, has been resolved, the Attorney General, respectfully, will not be filing an appellate brief.

Respectfully submitted,

Post Office Box 12548, Austin, Texas 78711-2548 • (512) 463-2100 • www.texasattorneygeneral.gov

Clerk of the Court Fifteenth Court of Appeals 15-25-00121-CV; Hays County, Texas, et al. v. Leslie Carnes, et al. Page 2

/s/ Lynn E. Saarinen LYNN E. SAARINEN Assistant Attorney General Texas Bar No. 1748900 General Litigation Division P.O. Box 12548 MC 019-1 Austin, Texas 78711-2548 Tel: (737) 224-4634 |Fax: (512) 477-2348 Lynn.saarinen@oag.texas.gov Counsel for Appellee, Ken Paxton, Attorney General of Texas

CERTIFICATE OF SERVICE

I certify that on November 18, 2025, the foregoing was filed and served on all parties of record via EFileTexas.gov.

/s/ Lynn E. Saarinen LYNN E. SAARINEN Assistant Attorney General

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.

Tristan Garza on behalf of Lynn Saarinen Bar No. 17498900 tristan.garza@oag.texas.gov Envelope ID: 108204252 Filing Code Description: Response Filing Description: Waiver Status as of 11/19/2025 8:11 AM CST

Associated Case Party: HAYS COUNTY

Name BarNumber Email TimestampSubmitted Status

Ian M.Davis idavis@mcginnislaw.com 11/18/2025 5:59:56 PM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Raymond Abarca Raymond.Abarca@oag.texas.gov 11/18/2025 5:59:56 PM SENT

Michael Shaunessy mshaunessy@mcginnislaw.com 11/18/2025 5:59:56 PM SENT

Julie Denny jdenny@mcginnislaw.com 11/18/2025 5:59:56 PM SENT

Amy Botelho abotelho@mcginnislaw.com 11/18/2025 5:59:56 PM SENT

Austin Jones ajones@mcginnislaw.com 11/18/2025 5:59:56 PM SENT

Bill Aleshire bill@aleshirelaw.com 11/18/2025 5:59:56 PM SENT

Bill Bunch bill@sosalliance.org 11/18/2025 5:59:56 PM SENT

Bobby Levinski bobby@sosalliance.org 11/18/2025 5:59:56 PM SENT

William Gammon firm@gammonlawoffice.com 11/18/2025 5:59:56 PM SENT

Lynn Saarinen lynn.saarinen@oag.texas.gov 11/18/2025 5:59:56 PM SENT

Rosemarie Kanusky rkanusky@mphlegal.com 11/18/2025 5:59:56 PM SENT

Matthew PhilipHines mhines@mphlegal.com 11/18/2025 5:59:56 PM SENT

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Hays County, Texas, Ruben Becerra, Debbie Ingalsbe, Michelle Cohen, Morgan Hammer, and Walt Smith, in Their Official Capacities v. Leslie Carnes, Jim Camp, Cathy Ramsey, Gabrielle Moore, and Ken Paxton, Attorney General of Texas, (Tex. Ct. App. 2025).

Hays County, Texas, Ruben Becerra, Debbie Ingalsbe, Michelle Cohen, Morgan Hammer, and Walt Smith, in Their Official Capacities v. Leslie Carnes, Jim Camp, Cathy Ramsey, Gabrielle Moore, and Ken Paxton, Attorney General of Texas (Hays County, Texas, Ruben Becerra, Debbie Ingalsbe, Michelle Cohen, Morgan Hammer, and Walt Smith, in Their Official Capacities v. Leslie Carnes, Jim Camp, Cathy Ramsey, Gabrielle Moore, and Ken Paxton, Attorney General of Texas) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.