Case Information
*0 FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS 7/17/2025 8:02:28 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 15-25-00086-Cv FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 7/17/2025 8:02 AM CHRISTOPHER A. PRINE CLERK Cause No. 15-25-00086 CV IN THE COURT OF APPEALS THIRTEENTH JUDICIAL DISTRICT OF AUSTIN TEXAS City of Grand Prairie, et al ., Appellants-Plaintiffs , City of Brownsville, et al ., Appellants – Intervenor Plaintiffs , Long Tail Trail Investments, LLC, Appellant – Intervenor Plaintiff , v.
The State of Texas, et al ., Appellant Defendants .
On appeal from the 261 st District Court of Travis County, Texas No. D-1-GN-23-007785, the Honorable Maria Cantú Hexsel presiding FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF BY APPELLANT – INTERVENOR PLAINITFF CITY OF BROWNSVILLE
MAY IT PLEASE THE COURT:
The City of Brownsville, Appellant – Intervenor Plaintiff, respectfully requests a
30-day extension of time to file its opening brief pursuant to Texas Rules of
Appellate Procedure 10.5(b), and in support thereof respectfully shows:
1. City of Brownsville filed a notice of appeal in the district court on June 6, 2025.
2. City of Brownsville’s opening brief was due on July 16, 2025. 3. City of Brownsville seeks an additional 30 days, through and until Friday, August 15, 2025, to file its opening brief.
4. City of Brownsville seeks an extension so that the briefing deadlines for all Appellant-Parties will be aligned and so that counsel for City of Brownsville may have adequate time to prepare the brief.
5. This Honorable Court has granted 30-day extensions to other Appellant- Parties. The requested additional time will facilitate necessary consultation between City of Brownsville and counsel, review of the record, and preparation of an opening brief that will most effectively assist the Court in its resolution of this appeal. The undersigned’s personal and professional obligations also spur this request.
6. This is City of Brownsville’s first request for an extension of time. 7. The other parties to this action have indicated that they are unopposed to this request for extension.
8. This extension is not sought for delay, but so that justice may be done.
City of Brownsville respectfully requests an extension of 30 days from the original
filing deadline to file its opening brief, through and until Friday, August 15, 2025.
Respectfully submitted, CITY OF BROWNSVILLE GUILLERMO “WILL” TREVIÑO CITY ATTORNEY State Bar No. 24044743 Litigation@brownsvilletx.gov Will.Trevino@brownsvilletx.gov (956) 548 – 6070 1001 East Elizabeth Street Brownsville, Texas 78520 /s/ Lena Chaisson-Muñoz ________________
___________________ Lena Chaisson-Muñoz Assistant City Attorney State Bar No. 24085244 Lena.Munoz@brownsvilletx.gov Jennifer Avendaño First Assistant City Attorney State Bar No. 24052304 Jennifer.Avendano@brownsvilletx.gov Criselda Rincon-Flores Assistant City Attorney State Bar No. 24049412 Criselda.Flores@brownsvilletx.gov CERTIFICATE OF SERVICE I certify that on June 27, 2025, the parties electronically conferred regarding
extensions of time to file openings briefs, and none were opposed.
/s/ Lena Chaisson-Muñoz ____________________ Lena Chaisson-Muñoz CERTIFICATE OF SERVICE I certify that on July 16, 2025, a true and correct copy of this Motion have been
submit to all attorneys of record via e-mail and/or electronic filing service of
process.
/s/ Lena Chaisson-Muñoz ____________________ Lena Chaisson-Muñoz *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.
Lena Chaisson-Muñoz on behalf of Lena Chaisson-Munoz
Bar No. 24085244
lena.munoz@brownsvilletx.gov
Envelope ID: 103240515
Filing Code Description: Motion
Filing Description: Motion for Extension of Time to File Opening Brief by
City of Brownsville
Status as of 7/17/2025 8:07 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Allison Collins 24127467 Acollins@fosterswift.com 7/17/2025 8:02:28 AM SENT
Lena Chaisson-Munoz lena.munoz@brownsvilletx.gov 7/17/2025 8:02:28 AM SENT
Raymond Abarca Raymond.Abarca@oag.texas.gov 7/17/2025 8:02:28 AM SENT
Cole Wilson Cole.Wilson@oag.texas.gov 7/17/2025 8:02:28 AM SENT
Will S.Trevino will.trevino@brownsvilletx.gov 7/17/2025 8:02:28 AM SENT
Sherry Brown sherry@txmunicipallaw.com 7/17/2025 8:02:28 AM SENT
Andy Messer andy@txmunicipallaw.com 7/17/2025 8:02:28 AM SENT
Brad Bullock brad@txmunicipallaw.com 7/17/2025 8:02:28 AM SENT
Timothy Dunn Taddunn@txmunicipallaw.com 7/17/2025 8:02:28 AM SENT
Todd Disher todd@lehotskykeller.com 7/17/2025 8:02:28 AM SENT
William Thompson will@lkcfirm.com 7/17/2025 8:02:28 AM SENT
Cole Wilson cole.wilson@oag.texas.gov 7/17/2025 8:02:28 AM SENT
Guillermo Trevino will.trevino@brownsvilletx.gov 7/17/2025 8:02:28 AM SENT
Lena Chaisson-Munoz lena.munoz@brownsvilletx.gov 7/17/2025 8:02:28 AM SENT
George Hyde ghyde@txlocalgovlaw.com 7/17/2025 8:02:28 AM SENT
Matthew Weston mweston@txlocalgovlaw.com 7/17/2025 8:02:28 AM SENT
David Overcash david.overcash@wtmlaw.net 7/17/2025 8:02:28 AM SENT
Clark McCoy cmccoy@wtmlaw.net 7/17/2025 8:02:28 AM SENT