State of Texas v. Xerox Corporation Settlement Proceeds

Opinion

ACCEPTED 15-25-00034-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 6/2/2025 9:29 AM No. 15-25-00034-CV CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS In the Fifteenth Court of Appeals AUSTIN, TEXAS Austin, Texas 6/2/2025 9:29:19 AM CHRISTOPHER A. PRINE Clerk The State of Texas Appellant, v. Xerox Corporation, et al, Settlement Proceeds Appellees.

On Appeal from the 459th Judicial District Court, Travis County

APPELLANT’S UNOPPOSED MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF

KEN PAXTON BRIAN VANDERZANDEN Attorney General of Texas Assistant Attorney General Texas State Bar No. 24081557 BRENT WEBSTER Phone: (512) 936-9929 First Assistant Attorney General Brian.Vanderzanden@oag.texas.gov

RALPH MOLINA JONATHAN ROHDE Deputy First Assistant Attorney General Assistant Attorney General Texas State Bar No. 00789965 AUSTIN KINGHORN Phone: (512) 936-1486 Deputy Attorney General for Civil Litigation Jonathan.Rohde@oag.texas.gov

AMY SNOW HILTON Counsel for Appellant Chief, Healthcare Program Enforcement Division

Office of the Attorney General of Texas P.O. Box 12548 MC 056-1 Austin, Texas 78711-2548 Tel: (512) 936-1709 Fax: (512) 499-0712 APPELLANT’S UNOPPOSED MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF

TO THE HONORABLE FIFTEENTH COURT OF APPEALS: 1. Pursuant to Rules 2 and 10.5(b) of the Texas Rules of Appellate Procedure, Appellant the

State of Texas respectfully requests a 30-day extension of time to file their Appellant Brief, making

the Brief due on July 9, 2025. The Appellant’s Brief is presently due on June 9, 2025.

2. Appellant requests an additional thirty (30) day extension of time to file their Appellant

Brief because the complete Clerk’s Record has not yet been received by the Fifteenth Court of

Appeals. The trial court only recently signed an order on May 28, 2025, releasing certain video

exhibits.

3. Additionally, Appellant requests an additional thirty (30) day extension of time to file their

Appellant Brief due to the complexity of the case, competing demands on counsel’s time in other

cases, and the need for additional research to ensure an optimal brief.

4. Appellees have indicated that they do not oppose a thirty (30) day extension for Appellant

to file its Appellant Brief.

5. This Motion is timely filed and not brought for purposes of delay, but so that justice may

be done.

1 PRAYER

For the reasons set forth herein, the Appellant the State of Texas respectfully requests

that the Court grant them a 30-day extension of time to file its Appellant Brief, making the Brief

due on July 9, 2025.

Respectfully submitted,

KEN PAXTON /s/ Brian VanderZanden Attorney General of Texas BRIAN VANDERZANDEN Assistant Attorney General BRENT WEBSTER Texas State Bar No. 24081557 First Assistant Attorney General Phone: (512) 936-9929 Brian.Vanderzanden@oag.texas.gov RALPH MOLINA Deputy First Assistant Attorney General /s/ Johnathan Rohde JOHNATHAN ROHDE AUSTIN KINGHORN jonathan.rohde@oag.texas.gov Deputy Attorney General for Civil Litigation COUNSEL FOR APPELLANT AMY SNOW HILTON STATE OF TEXAS Chief, Healthcare Program Enforcement Division

Office of the Attorney General P.O. Box 12548, MC 056-1 Austin, Texas 78711-2548 Tel: (512) 750-4880 Fax: (512) 499-0712

2 CERTIFICATE OF SERVICE

I certify a true and correct copy of the foregoing Appellant’s Unopposed Motion to Extend Time to File Appellant’s Brief has been sent via e-file and serve on June 2, 2025, to:

Charles S. Siegel Caitlyn Silhan Waters & Kraus, LLP 3141 Hood Street, Suite 700 Dallas, Texas 75219 csiegel@waterskraus.com csilhan@waterskraus.com

James Moriarty Law Offices of James R. Moriarty 4119 Montrose Blvd., Suite 250 Houston, Texas 7700 jim@moriarty.com

James “Rusty” Tucker Law Offices of James R. Tucker, P.C. 3100 Drexel Drive Dallas, Texas 75205 rusty@rustytuckerlaw.com

ATTORNEYS FOR APPELLEES

/s/ Brian VanderZanden Brian VanderZanden Assistant Attorney General

3 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.

Lynette Karch-Schroder on behalf of Brian VanderZanden Bar No. 24081557 Lynette.karch-schroder@oag.texas.gov Envelope ID: 101482362 Filing Code Description: Motion Filing Description: Appellant's Unopposed Motion to Extend Time to File Appellant's Brief Status as of 6/2/2025 9:34 AM CST

Associated Case Party: Christine Ellis

Name BarNumber Email TimestampSubmitted Status

Caitlyn Silhan 24072879 csilhan@waterskraus.com 6/2/2025 9:29:19 AM SENT

James Moriarty 14459000 jim@moriarty.com 6/2/2025 9:29:19 AM SENT

Charles S.Siegel csiegel@waterskraus.com 6/2/2025 9:29:19 AM SENT

Associated Case Party: Alexandra Alvarez

Name BarNumber Email TimestampSubmitted Status

James Tucker 20272020 rusty@rustytuckerlaw.com 6/2/2025 9:29:19 AM SENT

Associated Case Party: Joshua LaFountain

Name BarNumber Email TimestampSubmitted Status

James Tucker 20272020 rusty@rustytuckerlaw.com 6/2/2025 9:29:19 AM SENT

Associated Case Party: State of Texas

Name BarNumber Email TimestampSubmitted Status

Brian Vanderzanden brian.vanderzanden@oag.texas.gov 6/2/2025 9:29:19 AM SENT

Brittany Peters Brittany.Peters@oag.texas.gov 6/2/2025 9:29:19 AM SENT

Jonathan Rohde jonathan.rohde@oag.texas.gov 6/2/2025 9:29:19 AM SENT