The State of Texas v. City of Dallas; Eric Johnson, Mayor of Dallas; Tennell Atkins, Mayor Pro Tem of Dallas; Chad West, Jesse Moreno, Zarin D. Gracey, Carolyn King Arnold, Jaime Resendez, Omar Narvaez, Adam Bazaldua, Paula Blackmon, Kathy Stewart, Jaynie Schultz, Cara Mendelsohn, Gay Donnell Willis, and Paul E. Ridley, Members of the City Council of Dallas; Kimberly Bizol Tolbert, Interim City Manager of Dallas; And Michael T. Igo, Interim Chief of Police of Dallas; In Their Official Capacities

Opinion

ACCEPTED 15-25-00062-cv FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 5/2/2025 11:42 AM No. 15-25-00062-CV CHRISTOPHER A. PRINE CLERK

In the Court of Appeals 15th COURT FILED IN OF APPEALS

for the Fifteenth Judicial District5/2/2025 11:42:27 AM AUSTIN, TEXAS

Austin, Texas CHRISTOPHER A. PRINE Clerk

State of Texas, Appellant. v. CITY OF DALLAS, ET AL., Appellees.

On Appeal from the 134th Judicial District Court, Dallas County

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

TO THE HONORABLE FIFTH COURT OF APPEALS: Appellant, the State of Texas (Texas) respectfully requests that the Court ex- tend the time for the filing of Appellant’s Brief on the Merits by thirty (30) days to June 4, 2025. Under the current schedule, Texas’s brief is due on May 5, 2025. This is the State’s second request for an extension of time to file its brief.

B ACKGROUND Texas filed its notice of appeal in the district court on March 19, 2025. The

Reporter’s Record was filed on March 25, 2025, and the Clerk’s Record was filed on March 26, 2025. Due to an inadvertent clerical error, Texas filed its appeal with the Fifth Court of Appeals instead of the Fifteenth Court of Appeals. Consequently, Texas moved

on March 25, 2025, to transfer the appeal to the Fifteenth Court of Appeals. On April 1, 2025, this Court sent a letter to the Clerk of the Fifteenth Court of Appeals grant- ing Texas’s motion to transfer. See Tex. R. App. P. 27a(c)(1)(B). The case was offi- cially transferred on April 23, 2025.

F ACTS The State requests an extension not for purposes of delay, but so that its coun- sel may have adequate time to prepare its brief in light of the undersigned counsel’s involvement in the statewide federal redistricting trial that will take place from ap- proximately May 21, 2025, through June 14, 2025, in the Western District of Texas,

El Paso Division. See League of United Latin American Citizens, et al. v. Abbott, et al., Cause No. EP-21-cv-00259-DCG-JES-JVB [Lead Case]. Due to the imminency of this trial, the undersigned counsel has and will continue to have several pretrial dead- lines that cannot realistically be moved, including: • A deadline of May 2, 2025, to review and filing of deposition page and line designations for over fifty witnesses, as well as prepare and file pretrial ma- terials, including exhibits and exhibit lists. • A deadline of May 9, 2025, for the parties to object to the opposing Parties’ rule 26(a)(3) disclosures. See Fed. R. Civ. P. 26(a)(3).

• A deadline of May 14, 2025 to file a pretrial brief. Texas seeks this extension not for the purpose of delaying the proceeding, but so that justice may be done. Defendant-Appellees are unopposed to this motion

2 P RAYER Texas respectfully requests that the Court grant it an extension of time to filing its opening brief, and set the new date for June 4, 2025.

Date: May 2, 2025

Ken Paxton Attorney General of Texas

Brent Webster First Assistant Attorney General

Ralph Molina Deputy First Assistant Attorney General

Ryan D. Walters Deputy Attorney General for Legal Strategy

Ryan G. Kercher Chief, Special Litigation Division

/s/ Zachary L. Rhines Zachary L. Rhines Special Counsel State Bar No. 24116957 Zachary.Rhines@oag.texas.gov

Kyle S. Tebo Special Counsel State Bar No. 24137691 Kyle.Tebo@oag.texas.gov

Office of the Attorney General P.O. Box 12548 (MC 059) Austin, Texas 78711-2548 Tel.: (512) 936-1700 Fax: (512) 474-2697 COUNSEL FOR THE STATE OF TEXAS

3 C ERTIFICATE OF C ONFERENCE

I certify that on April 30, 2025, I conferred via telephone and email with counsel for Defendant-Appellees regarding the subject of this motion. Counsel indicated they do not oppose a request for a 30 day extension.

/s/ Zachary L. Rhines Z ACHARY L. R HINES Special Counsel

CERTIFICATE OF SERVICE

I hereby certify that on May 2, 2025, a true and correct copy of the foregoing document was served via the Court’s electronic filing system to all counsel of record.

ELIZABETH CHANDLER NICHOLAS D. PALMER Texas State Bar No. 24097484 Texas State Bar No. 24067814 elizabeth.chandler@dallas.gov nicholas.palmer@dallas.gov Assistant City Attorney Executive Assistant City Attorney STACY JORDAN RODRIGUEZ DALLAS CITY ATTORNEY’S OFFICE Texas State Bar No. 11016750 1500 Marilla St., Room 7DN stacy.rodriguez@dallas.gov Dallas, Texas 75201 Assistant City Attorney Phone: (214) 670-3519 ANDREW G. SPANIOL Fax: (214) 670-0622 Texas State Bar No. 24063012 COUNSEL FOR DEFENDANTS andrew.spaniol@dallas.gov Senior Assistant City Attorney /s/ Zachary L. Rhines Z ACHARY L. R HINES Special Counsel

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.

Bonnie Freymuth on behalf of Zachary Rhines Bar No. 24116957 bonnie.freymuth@oag.texas.gov Envelope ID: 100374773 Filing Code Description: Motion Filing Description: 2nd Motion for Extension of Time by The State of Texas Status as of 5/2/2025 12:08 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Zachary Rhines zachary.rhines@oag.texas.gov 5/2/2025 11:42:27 AM SENT

Kyle Tebo Kyle.Tebo@oag.texas.gov 5/2/2025 11:42:27 AM SENT

Bonnie Freymuth bonnie.freymuth@oag.texas.gov 5/2/2025 11:42:27 AM SENT

Stacy Rodriguez 11016750 stacy.rodriguez@dallascityhall.com 5/2/2025 11:42:27 AM SENT

Nicholas Palmer 24067814 nicholas.palmer@dallas.gov 5/2/2025 11:42:27 AM SENT

Elizabeth Chandler elizabeth.chandler@dallas.gov 5/2/2025 11:42:27 AM SENT

Andrew G.Spaniol andrew.spaniol@dallas.gov 5/2/2025 11:42:27 AM SENT