State of Texas, Acting by and Through the Texas Facilities Commission, for and on Behalf of the Texas Health and Human Services Commission; The Texas Facilities Commission; Mike Novak, in His Official Capacity as Executive Director of the Texas Facilities Commission; The Texas Health and Human Services Commission; And Rolland Niles in His Official Capacity as Deputy Executive Commissioner for the System Support Services Division of the Texas Health and Human Services Commission v. 8317 Cross Park, LLC

Court of Appeals of Texas·Decided August 14, 2025·No. 15-25-00012-CV·Published

Opinion

ACCEPTED 15-25-00012-cv FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 8/14/2025 3:20 PM No. 15-25-00012-CV CHRISTOPHER A. PRINE CLERK In the Fifteenth Court of Appeals FILED IN Austin, Texas 15th COURT OF APPEALS AUSTIN, TEXAS 8/14/2025 3:20:27 PM State of Texas; the Texas Facilities Commission; the Texas Health and Human CHRISTOPHER A. PRINE Services Commission; Mike Novak, in his Official Capacity as Executive Clerk Director of the Texas Facilities Commission; and Rolland Niles, in his Official Capacity as Deputy Executive Commissioner for the System Support Services Division of the Texas Health and Human Services Commission, Appellants, v. 8317 Cross Park LLC, Appellee.

On Appeal from Cause No. D-1-GN-23-006445 In the 98th Judicial District of Travis County, Texas

MOTION TO STRIKE APPELLEE’S SUR-REPLY

Ken Paxton Kimberly Gdula Attorney General of Texas Division Chief General Litigation Division Brent Webster First Assistant Attorney General Jennifer Cook Assistant Attorney General Ralph Molina Texas Bar No. 00789233 Deputy First Assistant Attorney P.O. Box 12548/Mail Stop 019-1 General Austin, Texas 78711-2548 Tel: (737) 230-4700 Austin Kinghorn Fax: (512) 302-0667 Deputy Attorney General for Civil jennifer.cook@oag.texas.gov Litigation Counsel for Appellants

15-25-0012-CV; State of Texas, et al. v. 8317 Cross Park LLC Motion to Strike Appellee’s Sur-Reply Page 1 of 12 Table of Contents

INTRODUCTION .....................................................................................................3

ARGUMENT & AUTHORITIES .............................................................................4

I. Appellee’s letter is a sur-reply that is procedurally impermissible. ................5

II. Appellee’s letter fails to identify exceptional circumstances necessitating a sur-reply. .................................................................................................................... 6

CONCLUSION ........................................................................................................11

CERTIFICATE OF CONFERENCE.......................................................................12

15-25-0012-CV; State of Texas, et al. v. 8317 Cross Park LLC Motion to Strike Appellee’s Sur-Reply Page 2 of 12 TO THE HONORABLE JUSTICES OF THE FIFTEENTH DISTRICT COURT OF APPEALS:

The State of Texas; the Texas Facilities Commission (“TFC”); the Texas

Health and Human Services Commission (“HHSC”); Mike Novak, in his official

capacity as Executive Commissioner of the TFC; and Rolland Niles, in his official

capacity as Deputy Executive Commissioner for the System Support Services

Division of HHSC (hereinafter “Appellants”), file this motion asking the Court to

strike Appellee 8317 Cross Park LLC’s (“Appellee’s”) impermissible sur-reply.

INTRODUCTION

“The rules of appellate procedure do not permit a sur-reply.” In re Jordan

Foster Constr., LLC, No. 08-22-00201-CV, 2023 WL 2366610, at *7 (Tex.

App.El Paso, 2023) (quoting In re KFC USA, Inc., No. 05-98-01116-CV, 1998

WL 427284, at *1 (Tex. App.—Dallas, 1998, orig. proceeding) (internal quotations

omitted). “Surreplies, and any other filing that serves purpose or has the effect of a

surreply, are highly disfavored, as they usually are a strategic effort by the

nonmovant to have the last word on a matter.” Larcher v. West, 147 F. Supp. 2d 538,

539 (N.D. Tex. 2001).

On February 5, 2025, Appellants filed their notice of interlocutory appeal

following the partial denial of Appellants’ plea to the jurisdiction. Appellants’

opening brief was filed on March 17, 2025, to which Appellee filed a response brief

15-25-0012-CV; State of Texas, et al. v. 8317 Cross Park LLC Motion to Strike Appellee’s Sur-Reply Page 3 of 12 on May 7, 2025. The Appellants then filed their reply on July 10, 2025, responding

to the arguments made by Appellee. In an attempt to get a second bite at the apple

and the last word, on July 31, 2025, without leave of Court, Appellee submitted a

letter (“Sur-Reply”) to this Court’s Clerk and requested that the Sur-Reply be

submitted to the Court. In the Sur-Reply, Appellee rehashes arguments previously

briefed by the parties and seeks to provide additional argument after the filing of

Appellants’ reply brief that was principally already included in Appellee’s

Response. The Texas Rules of Appellate Procedure do not contemplate giving a

party the opportunity to burden the court with unnecessary, duplicative briefing,

even in exceptional circumstances. Appellee’s letter to the Court is nothing more

than an impermissible sur-reply and Appellants respectfully ask the Court to strike

the Sur-Reply.

ARGUMENT & AUTHORITIES

As Appellee is likely aware, the Texas Rules of Appellate Procedure allow

the Appellant to have the first and last argument. See Tex. R. App. P. §§ 38.1-38.3.

The process and purpose are similar to that of a motion filed in district courtthe

“purpose for having a motion, response, and reply is to give the movant the final

opportunity to be heard, and to rebut the nonmovants’ response, thereby persuading

the court that the movant is entitled to the relief requested by the motion.” Info-

Power Int’l, Inc. v. Coldwater Tech., Inc., No. 3:07CV0937-P, 2008 WL 5552245,

15-25-0012-CV; State of Texas, et al. v. 8317 Cross Park LLC Motion to Strike Appellee’s Sur-Reply Page 4 of 12 at *8 (N.D. Tex., Dec. 31, 2008) (internal quotation marks omitted) (emphasis in

original). A sur-reply is only appropriate if the movant raises new legal theories or

introduces new evidence at the reply stage. Id. When a party does not raise “wholly

new issues in its reply brief” but “instead replies to arguments made by the

[nonmovant] in their response[,]” the court need not grant a motion for leave to file

a sur-reply. Mission Toxicology, LLC v. UnitedHealthcare Ins. Co., 499 F. Supp. 3d

350, 360 (W.D. Tex., Nov. 4, 2020).

A. Appellee’s letter is a sur-reply that is procedurally impermissible.

The Texas Rules of Appellate Procedure do not permit a sur-reply brief or a

filing that acts as a sur-reply. See In re Est. of Washington, 289 S.W.3d 362, 370

(Tex. App.Texarkana, 2009) (“Our Rules of Appellate Procedure do not expressly

permit the filing of a surreply brief by an appellee; such filings are permitted at this

Court's discretion.”); see also In re Jordan Foster Constr., LLC, 2023 WL 2366610,

at *7; Tex.R.App.P. §§ 38.1-38.3. Even when a sur-reply might be allowed, leave of

court for such additional briefing is required. In re Est. of Washington, 289 S.W.3d

at 370. Without leave of court and a showing of exceptional circumstances, striking

the filing is the appropriate remedy. In re Jordan Foster Constr., LLC, 2023 WL

2366610, at *7; In re Reiss, No. 05-21-00600-CV, 2022 WL 500023, at *1 (Tex.

App.—Dallas, 2022, orig. proceeding) (mem. op.); In re KFC USA, Inc., 1998 WL

427284, at *1 (Tex. App.—Dallas, 1998, orig. proceeding). Without leave of Court,

15-25-0012-CV; State of Texas, et al. v. 8317 Cross Park LLC Motion to Strike Appellee’s Sur-Reply Page 5 of 12 Appellee filed its letter brief with this Court with the specific intent of responding to

Appellants’ reply brief. Because Appellee did not seek leave of this Court to file its

Sur-Reply and instead chose to unilaterally circumvent these rules, striking

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State of Texas, Acting by and Through the Texas Facilities Commission, for and on Behalf of the Texas Health and Human Services Commission; The Texas Facilities Commission; Mike Novak, in His Official Capacity as Executive Director of the Texas Facilities Commission; The Texas Health and Human Services Commission; And Rolland Niles in His Official Capacity as Deputy Executive Commissioner for the System Support Services Division of the Texas Health and Human Services Commission v. 8317 Cross Park, LLC, (Tex. Ct. App. 2025).

State of Texas, Acting by and Through the Texas Facilities Commission, for and on Behalf of the Texas Health and Human Services Commission; The Texas Facilities Commission; Mike Novak, in His Official Capacity as Executive Director of the Texas Facilities Commission; The Texas Health and Human Services Commission; And Rolland Niles in His Official Capacity as Deputy Executive Commissioner for the System Support Services Division of the Texas Health and Human Services Commission v. 8317 Cross Park, LLC (State of Texas, Acting by and Through the Texas Facilities Commission, for and on Behalf of the Texas Health and Human Services Commission; The Texas Facilities Commission; Mike Novak, in His Official Capacity as Executive Director of the Texas Facilities Commission; The Texas Health and Human Services Commission; And Rolland Niles in His Official Capacity as Deputy Executive Commissioner for the System Support Services Division of the Texas Health and Human Services Commission v. 8317 Cross Park, LLC) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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