State of Texas, Maxx Juusola, Tracy Martin, and Alan Crider v. City of Dallas, Kimberly Bizor Tolbert, in Her Official Capacity as the Interim City Manager for the City of Dallas and the State Fair of Texas
Opinion
ACCEPTED 15-25-00122-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 9/22/2025 5:58 PM No. 15-25-00122-CV CHRISTOPHER A. PRINE CLERK IN THE COURT OF APPEALS FILED IN FOR THE FIFTEENTH JUDICIAL DISTRICT15th COURT OF APPEALS AUSTIN, TEXAS AUSTIN, TEXAS 9/22/2025 5:58:44 PM CHRISTOPHER A. PRINE Clerk STATE OF TEXAS, AND MAXX JUUSOLA, TRACY MARTIN, AND ALAN CRIDER, Appellants, v.
CITY OF DALLAS, KIMBERLY BIZOR TOLBERT, IN HER OFFICIAL CAPACITY AS THE INTERIM CITY MANAGER FOR THE CITY OF DALLAS, AND THE STATE FAIR OF TEXAS, Appellees.
On Appeal from the 298th Judicial District Court, Dallas County ____________________________________________________
APPELLANT STATE OF TEXAS’S FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF ____________________________________________________
TO THE HONORABLE FIFTEENTH COURT OF APPEALS:
Appellant, State of Texas (“State”) by and through Ken Paxton, Attorney
General of Texas (Appellant), respectfully requests an extension of time to Friday,
October 23, 2025, in which to file its brief in the captioned appeal. In support, the
State would show the Court as follows:
1. Appellant’s brief is currently due on September 25, 2025. Appellant
requests an extension of twenty-eight days. No previous extensions have been
requested or granted. 2. Counsel for Appellant is in need of an extension due to emergent
matters that arose in other cases which required a majority of his time before
September 25, 2025.
3. This motion is not interposed for the purpose of delay, but only to allow
counsel for the State to adequately prepare and file its brief.
4. Counsel for each Appellee has stated they do not oppose this request.
Appellant State of Texas therefore respectfully requests an extension of time
to and including Friday, October 23, 2025, in which to file and serve its brief in the
captioned appeal.
DATED: September 22, 2025.
2 Respectfully submitted,
KEN PAXTON Attorney General of Texas
BRENT WEBSTER First Assistant Attorney General
RALPH MOLINA Deputy First Assistant Attorney General
AUSTIN KINGHORN Deputy Attorney General for Civil Litigation
ERNEST C. GARCIA Chief, Administrative Law Division
/s/ Canon Parker Hill CANON PARKER HILL Assistant Attorney General State Bar No. 24140247 OFFICE OF THE ATTORNEY GENERAL OF TEXAS Administrative Law Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Telephone: (512) 936-1838 Facsimile: (512) 320-0167 Canon.hill@oag.texas.gov
Counsel for Appellant, State of Texas
3 CERTIFICATE OF CONFERENCE
I hereby certify that I contacted counsel Jeffery Tillotson for Appellee City of Dallas and Kimberly Tolbert in her official capacity as interim city manager, and counsel Jim Harris for Appellee State Fair of Texas, and that both counsels stated they are unopposed to the extension requested in this Motion.
/s/ Canon Parker Hill CANON PARKER HILL Assistant Attorney General
4 CERTIFICATE OF SERVICE
I hereby certify that, in compliance with Rule 9.5 of the Texas Rules of Appellate Procedure, a true and correct copy of the above and foregoing document has been served on the following on this the 4th day of November 2021:
Jeffrey Tillotson via e-service to: jtillotson@tillotsonlaw.com Tillotson, Johnson & Patton 1201 Main Street, Suite 1300 Dallas, Texas 75202 Counsel for City of Dallas and Kimberly Tolbert
Bryan Neal via e-service to: bryan.neal@hklaw.com Holland & Knight One Arts Plaza 1722 Routh Street, Suite 1500 Dallas, Texas 75201-2532 Counsel for State Fair of Texas
Tony K. McDonald via e-service to: Tony@tonymcdonald.com State Bar No. 24083477 Connor Ellington via e-service to: connor@tonymcdonald.com State Bar No. 24128592 The Law Offices of Tony McDonald 1308 Ranchers Legacy Trail Fort Worth, TX 76126 Counsel for Individual Plaintiffs /s/ Canon Parker Hill CANON PARKER HILL Assistant Attorney General
5 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.
Catherine Hughes on behalf of Canon Hill Bar No. 24140247 catherine.hughes@oag.texas.gov Envelope ID: 105930940 Filing Code Description: Motion Filing Description: Motion for Extension Status as of 9/23/2025 7:13 AM CST
Associated Case Party: City of Dallas
Name BarNumber Email TimestampSubmitted Status
Joseph AIrrobali airrobali@tillotsonlaw.com 9/22/2025 5:58:44 PM SENT
Nathaniel Buchheit nbuchheit@tillotsonlaw.com 9/22/2025 5:58:44 PM SENT
Megan Coker mcoker@tillotsonlaw.com 9/22/2025 5:58:44 PM SENT
Anne Johnson ajohnson@tillotsonlaw.com 9/22/2025 5:58:44 PM SENT
Jeffrey Tillotson 20039200 jtillotson@tillotsonlaw.com 9/22/2025 5:58:44 PM SENT
Associated Case Party: State Fair of Texas
Name BarNumber Email TimestampSubmitted Status
James Harris 9065400 jim.harris@hklaw.com 9/22/2025 5:58:44 PM SENT
Sherri Rodgers sherri.rodgers@hklaw.com 9/22/2025 5:58:44 PM SENT
Bryan Neal 788106 Bryan.Neal@hklaw.com 9/22/2025 5:58:44 PM SENT
Robert B.Smith Robert@Smith-Firm.com 9/22/2025 5:58:44 PM SENT
Associated Case Party: State of Texas
Name BarNumber Email TimestampSubmitted Status
Melissa Juarez melissa.juarez@oag.texas.gov 9/22/2025 5:58:44 PM SENT
Meridith Fischer Meridith.Fischer@oag.texas.gov 9/22/2025 5:58:44 PM SENT
Ernest Garcia ernest.garcia@oag.texas.gov 9/22/2025 5:58:44 PM SENT
Catherine Hughes catherine.hughes@oag.texas.gov 9/22/2025 5:58:44 PM SENT
Canon ParkerHill canon.hill@oag.texas.gov 9/22/2025 5:58:44 PM SENT
Steven Ogle Steven.Ogle@oag.texas.gov 9/22/2025 5:58:44 PM SENT 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.
Catherine Hughes on behalf of Canon Hill Bar No. 24140247 catherine.hughes@oag.texas.gov Envelope ID: 105930940 Filing Code Description: Motion Filing Description: Motion for Extension Status as of 9/23/2025 7:13 AM CST
Associated Case Party: State of Texas
Steven Ogle Steven.Ogle@oag.texas.gov 9/22/2025 5:58:44 PM SENT
Holly Dudrick holly.dudrick@oag.texas.gov 9/22/2025 5:58:44 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Kira Lytle klytle@tillotsonlaw.com 9/22/2025 5:58:44 PM SENT
TJP Service tillotsonjohnsonpatton@gmail.com 9/22/2025 5:58:44 PM SENT
William Cole William.Cole@oag.texas.gov 9/22/2025 5:58:44 PM SENT
William Peterson William.Peterson@oag.texas.gov 9/22/2025 5:58:44 PM SENT
Bryan Neal bryan.neal@hklaw.com 9/22/2025 5:58:44 PM SENT
Tony McDonald Tony@tonymcdonald.com 9/22/2025 5:58:44 PM SENT
Devlin Browne dbrowne@tillotsonlaw.com 9/22/2025 5:58:44 PM SENT
Associated Case Party: AlanCrider
Name BarNumber Email TimestampSubmitted Status
Connor Ellington connor@tonymcdonald.com 9/22/2025 5:58:44 PM SENT
Associated Case Party: MaxxJuusola
Name BarNumber Email TimestampSubmitted Status
Connor Ellington connor@tonymcdonald.com 9/22/2025 5:58:44 PM SENT
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State of Texas, Maxx Juusola, Tracy Martin, and Alan Crider v. City of Dallas, Kimberly Bizor Tolbert, in Her Official Capacity as the Interim City Manager for the City of Dallas and the State Fair of Texas (State of Texas, Maxx Juusola, Tracy Martin, and Alan Crider v. City of Dallas, Kimberly Bizor Tolbert, in Her Official Capacity as the Interim City Manager for the City of Dallas and the State Fair of Texas) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.