The State of Texas v. Patrick Cox, for Himself and as Agent for AOC Ranches, LLC, Team Advertising Services, Inc., CCLHR Enterprises, LLC and VPizza Restaurant 001, LLC

Opinion

ACCEPTED

15-25-00117-CV

FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 7/22/2025 12:51 PM

No. 15-25-00117-CV CHRISTOPHER A. PRINE CLERK

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

AUSTIN, TEXAS

for the Fifteenth Judicial District7/22/2025 12:51:09 PM CHRISTOPHER A. PRINE

Clerk

THE STATE OF TEXAS

Appellant/Cross-Appellees, v.

Patrick Cox, for himself and as agent for AOC Ranches, LLC, Team Advertising Services, Inc., CCLHR Enterprises , LLC and VPizza Restaurant 001, LLC, Appellees/Cross-Appellants.

On Appeal from the

419th Judicial District Court, Travis County Cause No. D-1-GN-19-000436

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF

In accordance with Texas Rule of Appellate Procedure 10.5(b), Appellant the State of Texas files this motion for extension of time to file its brief. Appellant’s

opening brief is currently due to be filed on July 28. Appellant requests a thirty-day

extension of this deadline, up to and including August 27. This is Appellant’s first

request for an extension for this filing, and it is unopposed.

This request is necessary due to Appellant’s counsel having been on sick leave

for a majority of the period to complete the brief. Appellant’s counsel also has mul-

tiple engagements that have required or will require significant attention, including:

 an opening brief on the merits in Anadarko v. Hegar, No. 24-0257, due to be filed in the Texas Supreme Court on July 22;

 assisting with emergency proceedings in Garza v. Paxton, No. 15-25-00116-CV, which included multiple filings in June and July; the opening brief is due to be filed in the Fifteenth Court of Appeals on July 28; and  a reply brief in Muth v. Voe, No. 24-0384, due to be filed in the Texas Supreme Court on August 11.

This extension is sought in the interest of justice, not for delay, and no party will

be prejudiced if this unopposed request is granted. An extension of time will allow

counsel for Appellant to prepare a thorough response that will be helpful to the

Court.

3

Prayer

For these reasons, Appellant respectfully requests that the Court grant its unop-

posed motion for a thirty-day extension of time to file its brief, resulting in a new

deadline of August 27, 2025.

Respectfully submitted.

Ken Paxton Attorney General of Texas William R. Peterson Solicitor General

Brent Webster First Assistant Attorney General /s/ Jacob C. Beach Jacob C. Beach

Office of the Attorney General Assistant Solicitor General P.O. Box 12548 (MC 059) State Bar No. 24116083 Austin, Texas 78711-2548 Jacob.Beach@oag.texas.gov Tel.: (512) 936-1700 Fax: (512) 474-2697 Counsel for Appellants

Certificate of Conference I certify that on July 22, 2025, I conferred with counsel for all parties, who in-

formed me that they do not oppose the extension sought through this motion.

/s/ Jacob C. Beach Jacob c. Beach

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.

Amanda Ruch on behalf of Jacob Beach Bar No. 24116083 amanda.ruch@oag.texas.gov Envelope ID: 103434134 Filing Code Description: Motion Filing Description: 20250718_Cox_MET_BoM_Final Status as of 7/22/2025 12:58 PM CST

Associated Case Party: Patrick Cox

Name BarNumber Email TimestampSubmitted Status

Reese Baker 1587700 courtdocs@bakerassociates.net 7/22/2025 12:51:09 PM SENT

Associated Case Party: The State of Texas

Name BarNumber Email TimestampSubmitted Status

Ali Thorburn ali.thorburn@oag.texas.gov 7/22/2025 12:51:09 PM SENT

Jacob Beach jacob.beach@oag.texas.gov 7/22/2025 12:51:09 PM SENT

Amanda Ruch amanda.ruch@oag.texas.gov 7/22/2025 12:51:09 PM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Ariana Ines ariana.ines@oag.texas.gov 7/22/2025 12:51:09 PM SENT