Richard A. Hyde, P.E., in His Official Capacity as Executive Director of the Texas Commission on Environmental Quality; And the Texas Commission on Environmental Quality v. Harrison County, Texas

Opinion

ACCEPTED 15-24-00014-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 4/2/2025 10:00 AM No. 15-24-00014-CV CHRISTOPHER A. PRINE _____________________________________________________________ CLERK FILED IN 15th COURT OF APPEALS IN THE FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS _____________________________________________________________ 4/2/2025 10:00:07 AM CHRISTOPHER A. PRINE Clerk RICHARD A. HYDE, P.E., IN HIS OFFICIAL CAPACITY AS EXECUTIVE DIRECTOR OF THE TEXAS COMMISSION ON ENVIRONMENTAL QUALITY; AND THE TEXAS COMMISSION ON ENVIRONMENTAL QUALITY, Appellants, V.

HARRISON COUNTY, TEXAS, Appellee. _____________________________________________________________

On Appeal from the 353rd District Court Travis County, Texas Trial Court Cause No. D-1-GN-17-002026 _____________________________________________________________

UNOPPOSED MOTION FOR EXTENSION TO FILE MOTION FOR REHEARING

TO THE HONORABLE COURT OF APPEALS:

Appellee Harrison County, Texas files this unopposed motion for extension

to file Motion for Rehearing under Texas Rule of Appellate Procedure 10.5 and

respectfully requests a 17-day extension, until and including Monday, April 21,

2025, to file its motion for rehearing.

Motion for Extension to File Motion for Rehearing Page 1 I.

Appellee’s motion for rehearing is currently due on April 4, 2025. Appellee

seeks a seventeen-day extension, which would make the brief due Monday, April

21, 2025.

II.

The extension is not sought for delay, and no party will be prejudiced if it is

granted. Appellant and all other parties are unopposed to this request. This is

Appellee’s first request for extension. Appellee’s counsel is actively involved in a

hearing in complex litigation as lead counsel in SAVERGV, Sierra Club, and

Carrizo/Comecrudo Nation of Texas, Inc. v. Cameron County, Texas pending an

appeal to the Texas Supreme Court, Cause No. 2021-060150, Union Pacific

Railroad Company v. Anderson County, et al on appeal to the Texas Supreme Court,

Maurial, et al v. Baxter & Chavigny, in the 394th District Court of Presidio County,

Case No. 24-03-00087CVF, and Frio County, Texas v. US Casualty and Surety

Insurance Company, in the 81st/218th District Court of Frio County.

III.

Accordingly, Appellee seeks a seventeen-day extension, yielding a new due

date for the Motion for Rehearing of April 21, 2025.

Motion for Extension to File Motion for Rehearing Page 2 IV.

The parties have conferred, and Counsel for Appellant, Jake Marx, Assistant

Attorney General, and counsel for all parties are unopposed to this motion.

PRAYER

Appellee requests that the Court grant a seventeen-day extension of time to

file Motion for Rehearing, making it due on April 21, 2025.

Respectfully submitted, /s/ James P. Allison James P. Allison SBN: 01090000 j.allison@allison-bass.com J. Eric Magee SBN: 24007585 e.magee@allison-bass.com ALLISON, BASS & MAGEE, LLP 1301 Nueces Street, Suite 201 Austin, Texas 78701 (512) 482-0701 telephone (512) 480-0902 facsimile

CERTIFICATE OF CONFERENCE I certify that I conferred on April 2, 2025 with counsel for Appellant and counsel for all other parties by email. Counsel does not oppose this motion. /s/ James P. Allison_________ James P. Allison

Motion for Extension to File Motion for Rehearing Page 3 CERTIFICATE OF SERVICE I certify that a copy of Appellee’s Motion for Extension of Time to File Motion for Rehearing was served on Appellant electronically on this 2nd day of April, 2025 to the following:

Jake Marx Assistant Attorney General Jake.Marx@oag.texas.gov Shelby Thompson Assistant Attorney General Shelby.Thompson@oag.texas.gov Office of the Attorney General Environmental Protection Division P.O. Box 12548, MC 066 Austin, Texas 78711-2548

/s/ James P. Allison James P. Allison

Motion for Extension to File Motion for Rehearing Page 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.

Legal Secretary on behalf of James Allison Bar No. 1090000 allison.bass@allison-bass.com Envelope ID: 99172226 Filing Code Description: Motion Filing Description: Unopposed Motion for Extension to File Motion for Rehearing Status as of 4/2/2025 10:12 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

James P. Allison j.allison@allison-bass.com 4/2/2025 10:00:07 AM SENT

Legal Secretary allison.bass@allison-bass.com 4/2/2025 10:00:07 AM SENT

irene tong irene.tong@oag.texas.gov 4/2/2025 10:00:07 AM SENT

Julia McVey j.mcvey@allison-bass.com 4/2/2025 10:00:07 AM SENT

Jake Marx jake.marx@oag.texas.gov 4/2/2025 10:00:07 AM SENT

Susana Naranjo-Padron s.naranjo-padron@allison-bass.com 4/2/2025 10:00:07 AM SENT

Shelby Thompson shelby.thompson@oag.texas.gov 4/2/2025 10:00:07 AM SENT

James ScottMcCarley scott.mccarley@oag.texas.gov 4/2/2025 10:00:07 AM SENT