Brandon Hodges, Individually and in His Official Capacity as Trustee of District for Midland ISD; Dr. Mary Bone, Individually and in Her Official Capacity as a Trustee of Round Rock ISD; And Danielle Weston, Individually and in Her Official Capacity as a Trustee of Round Rock ISD v. Pecos-Barstow-Toyah Independent School District, Crandall Independent School District, Forney Independent School District, Fort Stockton Independent School District, and Kingsville Independent School District

ACCEPTED 15-24-00109-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 3/31/2025 11:47 AM NO. 15-24-00109-CV CHRISTOPHER A. PRINE CLERK FILED IN IN THE COURT OF APPEALS 15th COURT OF APPEALS FOR THE FIFTEENTH DISTRICT OF TEXASAUSTIN, TEXAS AT AUSTIN 3/31/2025 11:47:54 AM CHRISTOPHER A. PRINE Clerk BRANDON HODGES, INDIVIDUALLY AND IN HIS OFFICIAL CAPACITY AS TRUSTEE OF DISTRICT FOR MIDLAND ISD; DR. MARY BONE, INDIVIDUALLY AND IN HER OFFICIAL CAPACITY AS A TRUSTEE OF ROUND ROCK ISD; AND DANIELLE WESTON, INDIVIDUALLY AND IN HER OFFICIAL CAPACITY AS A TRUSTEE OF ROUND ROCK ISD, Appellants, v. PECOS-BARSTOW-TOYAH INDEPENDENT SCHOOL DISTRICT; CRANDALL INDEPENDENT SCHOOL DISTRICT; FORNEY INDEPENDENT SCHOOL DISTRICT, FORT STOCKTON INDEPENDENT SCHOOL DISTRICT; AND KINGSVILLE INDEPENDENT SCHOOL DISTRICT, Appellees.

Appeal from the 201st Judicial District Court Travis County, Texas Cause No. D-1-GN-24-005018

APPELLANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF

TO THE HONORABLE COURT OF APPEALS: Appellants Brandon Hodges individually and in his official capacity as Trustee of District for Midland ISD, Dr. Mary Bone individually and in her official

APPELLANTS’ MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ REPLY BRIEF PAGE 1 capacity as a Trustee of Round Rock ISD, and Danielle Weston individually and in her official capacity as a Trustee of Round Rock ISD (collectively “Appellants”) file this Unopposed Motion for Extension of Time to File Appellants’ Reply Brief and shows: I. SUMMARY OF MOTION Appellants’ Reply Brief in the above matter is due on March 31, 2025.

Appellants request a 20-day extension, moving the deadline to April 21, 2025. 1 This is Appellants’ first request for an extension of time to file their Reply Brief. This motion is unopposed.

II. ARGUMENT AND AUTHORITIES The Texas Rules of Appellate Procedure allow for the extension of a party’s briefing deadline upon a motion under Rule 10.5(b). TEX. R. APP. P. 38.6(d) (citing TEX. R. APP. P. 10.5(b)). Under Rule 10.5(b), the movant must identify the existing deadline, the length of the extension requested, the factual basis for the extension, and the number of prior extensions granted for the same deadline. TEX. R. APP. P. 10.5(b).

This is Appellants’ first requested extension, and the length of the extension sought is 20 days. If this motion is granted, Appellants’ Reply Brief will be due on April 21, 2025. Appellees do not oppose the requested extension.

Twenty days from March 31, 2025 is Sunday, April 20, 2025, thus, the date upon which the Reply Brief would be due is April 21, 2025. See TEX. R. APP. P. 4.1(a).

APPELLANTS’ MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ REPLY BRIEF PAGE 2 Counsel for Appellants request an extension due to deadlines that have hindered their completion of Appellants’ Brief in this matter. Lead counsel in this case, Byron K. Henry, has had a number of other deadlines and requirements precluding his ability to complete the Brief by the deadline, including the following: • Out of the office on pre-paid family vacation March 10-14, 2025.

• Prepare for and file Petition for Writ of Mandamus and Motion for Temporary Relief on March 18, 2025 in Case No. 05-25-00319-CV, before the Fifth District Court of Appeals at Dallas, Texas.

• Prepare for and attend hearing on Motion for Summary Judgment on March 19, 2025, in Cause No. 096-341756-23, in the 96th District Court, Tarrant County, Texas.

• Prepare for and attend Jury Trial on March 24, 2025, in Cause No. 429- 06415-2019, in the 429th District Court, Collin County, Texas.

Counsel for Appellants Walker Young also has had to attend to several deadlines that have hindered and will hinder his work to complete Appellants’ Reply Brief and has been engaged in preparing the same briefs. Mr. Young was also out of the office on a pre-paid family vacation from March 10, 2025 through March 14, 2025.

For these reasons, a 20-day extension of time is needed to complete Appellants’ Reply Brief in this matter. This extension is not sought for delay but so that justice may be done.

APPELLANTS’ MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ REPLY BRIEF PAGE 3 III. CONCLUSION AND PRAYER For these reasons, Appellants Brandon Hodges individually and in his official capacity as Trustee of District for Midland ISD, Dr. Mary Bone individually and in her official capacity as a Trustee of Round Rock ISD, and Danielle Weston individually and in her official capacity as a Trustee of Round Rock ISD respectfully request the Court GRANT their Unopposed Motion for Extension of Time to File Appellants’ Reply Brief, order the Brief due on or before April 21, 2025, and grant Appellants such other relief to which they may be justly entitled.

Respectfully submitted,

By: BYRON K. HENRY State Bar No. 24008909 [email protected] WALKER STEVEN YOUNG State Bar No. 24102676 [email protected] SCHEEF & STONE, L.L.P. 2600 Network Blvd., Suite 400 Frisco, Texas 75034 (214) 472-2100 Phone (214) 472-2150 Fax ATTORNEYS FOR APPELLANTS

APPELLANTS’ MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ REPLY BRIEF PAGE 4 CERTIFICATE OF CONFERENCE I hereby certify that I conferred with Appellees’ counsel on March 31, 2025 and Appellees are unopposed to the relief requested in this motion. Certified to on March 31, 2025.

/s/ Walker Steven Young WALKER STEVEN YOUNG

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of this document has been delivered pursuant to TEX. R. APP. P. 9.5 to all counsel as indicated below on March 31, 2025: Via Electronic Filing/Service David J. Campbell [email protected] Kevin O’Hanlon [email protected] O’HANLON, DEMERATH & CASTILLO West Ave. Austin, Texas 78701 ATTORNEYS FOR APPELLEES

Byron K. Henry

APPELLANTS’ MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ REPLY BRIEF PAGE 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.

Melissa Diaz on behalf of Byron Henry Bar No. 24008909 [email protected] Envelope ID: 99072069 Filing Code Description: Motion Filing Description: Appellants' Unopposed Motion for Extension of Time to File Reply Brief Status as of 3/31/2025 1:25 PM CST Associated Case Party: Brandon Hodges, individually and in his official capacity as Trustee of District for Midland ISD Name BarNumber Email TimestampSubmitted Status Byron K.Henry [email protected] 3/31/2025 11:47:54 AM SENT Melissa Diaz [email protected] 3/31/2025 11:47:54 AM SENT Walker StevenYoung [email protected] 3/31/2025 11:47:54 AM SENT

Associated Case Party: Pecos-Barstow-Toyah Independent School District Name BarNumber Email TimestampSubmitted Status Kevin O'Hanlon 15235500 [email protected] 3/31/2025 11:47:54 AM SENT Lea Ohrstrom [email protected] 3/31/2025 11:47:54 AM SENT David Campbell [email protected] 3/31/2025 11:47:54 AM SENT Edward Smith [email protected] 3/31/2025 11:47:54 AM SENT