Crowley Independent School District v. Carl Stoneham, and Mike Morath, in His Official Capacity as Commissioner of Education of Texas

ACCEPTED 15-24-00051-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 12/18/2024 4:46 PM No. 15-24-00051-CV CHRISTOPHER A. PRINE ________________________________________________________________________ CLERK FILED IN 15th COURT OF APPEALS IN THE COURT OF APPEALS AUSTIN, TEXAS FOR THE FIFTEENTH JUDICIAL DISTRICT 12/18/2024 4:46:20 PM AUSTIN, TEXAS CHRISTOPHER A. PRINE Clerk __________________________________________________________________ Crowley Independent School District Appellant v. Carl Stoneham and Mike Morath, in his official capacity as Commissioner of Education of Texas Appellees __________________________________________________________________ On Appeal from the 48th District Court of Tarrant County No. 048-336026-22, Hon. Chris Taylor, Judge Presiding __________________________________________________________________ APPELLANT’S UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE MOTION FOR REHEARING __________________________________________________________________ TO THE HONORABLE FIFTEENTH COURT OF APPEALS: Pursuant to Texas Rules of Appellate Procedure 49.9, Appellant Crowley Independent School District seeks a 7-day extension to file its motion for rehearing, resulting in a new deadline of December 26, 2024.

The current deadline for filing Appellant’s motion for rehearing is December 19, 2024.

Counsel for Appellant has recently had numerous settings and deadlines in other matters. As a result, counsel requests an extension to ensure that Appellant provides the Court with a thorough, thoughtful, and well-composed motion for rehearing.

The undersigned has conferred with Appellees’ counsel, who indicated Appellees are not opposed to this request.

This is Appellant’s second request for an extension for this filing, and its granting will prejudice no party.

Accordingly, Appellant respectfully requests a 7-day extension of time to file its motion for rehearing, resulting in a new deadline of December 26, 2024.

Respectfully submitted, /s/ David J. Campbell David J. Campbell [email protected] State Bar No. 24057033 O’Hanlon, Demerath & Castillo West Ave. Austin, Texas, 78701 Tel: (512) 494-9949 Fax: (512) 494-9919 Counsel for Appellant Crowley Independent School District

CERTIFICATE OF CONFERENCE I certify that on or about December 17 and 18, 2024, I conferred by email with counsel for Appellee Morath and Appellee Stoneham, who indicated that Appellees are not opposed to the requested extension of 7 days.

/s/ David J. Campbell David J. Campbell

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served through the court’s e-filing/notice system on December 18, 2024 to the following: Daniel A. Ortiz Martin Cohick [email protected] [email protected] Giana Ortiz James Brazell [email protected] [email protected] The Ortiz Law Firm Office of the Attorney General Of 1304 West Abram Street Texas Suite 100 P.O. Box 12548, Capitol Station Arlington, TX 76013 Austin, TX 78711 Counsel for Appellee Carl Counsel for Appellee Mike Stoneham Morath

/s/ David J. Campbell David J. Campbell

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.

Kathryn French on behalf of David Campbell Bar No. 24057033 [email protected] Envelope ID: 95475260 Filing Code Description: Motion Filing Description: CISD's 2nd Unopposed MET Status as of 12/18/2024 4:52 PM CST Associated Case Party: Crowley Independent School District Name BarNumber Email TimestampSubmitted Status David Campbell [email protected] 12/18/2024 4:46:20 PM SENT Kathryn French [email protected] 12/18/2024 4:46:20 PM SENT

Associated Case Party: Carl Stoneham Name BarNumber Email TimestampSubmitted Status Daniel Ortiz [email protected] 12/18/2024 4:46:20 PM SENT Giana Ortiz [email protected] 12/18/2024 4:46:20 PM SENT

Associated Case Party: Mike Morath Name BarNumber Email TimestampSubmitted Status Meridith Fischer [email protected] 12/18/2024 4:46:20 PM SENT Elizabeth Chipelo [email protected] 12/18/2024 4:46:20 PM SENT James Z.Brazell [email protected] 12/18/2024 4:46:20 PM SENT Martin Cohick [email protected] 12/18/2024 4:46:20 PM SENT