Texas State University and Texas State University System v. Stuart Patrick Wilkinson

ACCEPTED 15-25-00028-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 4/21/2025 11:00 AM No. 15-25-00028-CV CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS In the Court of Appeals AUSTIN, TEXAS for the Fifteenth Judicial District 4/21/2025 11:00:55 AM Austin, Texas CHRISTOPHER A. PRINE Clerk

TEXAS STATE UNIVERSITY AND TEXAS STATE UNIVERSITY SYSTEM, Defendants-Appellants, v. STUART PATRICK WILKINSON, Plaintiff-Appellee. ______________________________ On Appeal from the 22nd Judicial District Court of Hays County, Texas ______________________________ JOINT MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ AND APPELLEE’S BRIEFS

TO THE HONORABLE FIFTEENTH COURT OF APPEALS: Defendants-Appellants, Texas State University and Texas State University System (“Appellants”) and Plaintiff-Appellee, Stuart Patrick Wilkinson (“Appellee”), bring this joint motion to request extension of the deadlines to file their respective briefs in this matter pursuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), and respectfully shows the Court the following:

-1- 1. The deadline for filing Appellants’ Brief is set for April 21, 2025.

2. Appellants request a 7-day extension to this deadline, or until Monday, April 28, 2025.

3. Lead counsel for Appellants needs more time to prepare Appellants’ Brief due to conflicting deadlines in her caseload and a recent move.

These issues demand her time and attention and serve as good cause for extending the time to file Appellant’s brief.

4. This is the first request for an extension.

5. This motion is unopposed.

6. The deadline for filing Appellee’s Brief is set for Monday, May 12, 2025.

7. Appellee requests a 14-day deadline, or until Monday, May 26, 2025.

8. Lead counsel for Appellee needs more time to prepare Appellee’s Brief due to conflicting deadlines in his caseload. These issues demand his time and attention and serve as good cause for extending the time to file Appellee’s brief.

The requested extensions are reasonable and necessary to allow Appellants and Appellee adequate time to prepare their respective briefs.

These requests are not made for delay, but only so that justice may be done.

-2- PRAYER For these reasons, Defendants-Appellants respectfully requests that this Court grant a 7-day extension of time to file Appellants’ Brief in this matter, to Monday, April 28, 2025; and Plaintiff-Appellee respectfully requests that this Court grant a 14-day extension of time to file Appellee’s Brief in this matter, to Monday, April 26, 2025.

Respectfully agreed and submitted, /s/ David Junkin (signed with permission) DAVID JUNKIN McGlothin Junkin & Wilde, PC W. San Antonio, Suite 400 San Marcos, Texas 78666 (512) 392-7510 (512) 395-7520 Fax [email protected] Counsel for Plaintiff-Appellee Stuart Patrick Wilkinson /s/ Rachel L. Behrendt RACHEL L. BEHRENDT Texas Bar No. 24130871 Assistant Attorney General P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Telephone: (512) 475-4112 Facsimile: (512) 320-0667 [email protected]

-3- Counsel for Defendants-Appellants Texas State University and Texas State University System CERTIFICATE OF CONFERENCE I certify that I conferred with David Junkin, counsel for Appellee- Plaintiff, via email on April 18, 2025, regarding the substance of this motion, and he stated that he is not opposed to this motion or the relief requested herein.

/s/ Rachel L. Behrendt RACHEL L BEHRENDT Assistant Attorney General

CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing document has been filed via the Court’s electronic filing system to all counsel of record on April 21, 2025.

David Junkin McGlothin Junkin & Wilde, PC W. San Antonio, Suite 400 San Marcos, Texas 78666 (512) 392-7510 (512) 395-7520 Fax [email protected] Counsel for Plaintiff-Appellee /s/ Rachel L. Behrendt RACHEL L BEHRENDT Assistant Attorney General

-4- 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.

Ariana Ines on behalf of Rachel Behrendt Bar No. 24130871 [email protected] Envelope ID: 99874504 Filing Code Description: Motion Filing Description: JOINT MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS AND APPELLEES BRIEFS Status as of 4/21/2025 11:02 AM CST Associated Case Party: Texas State University System Name BarNumber Email TimestampSubmitted Status Rachel L. Behrendt [email protected] 4/21/2025 11:00:55 AM SENT

Associated Case Party: Texas State University Name BarNumber Email TimestampSubmitted Status Rachel L. Behrendt [email protected] 4/21/2025 11:00:55 AM SENT

Case Contacts Name BarNumber Email TimestampSubmitted Status Ariana Ines [email protected] 4/21/2025 11:00:55 AM SENT

Associated Case Party: StuartPatrickWilkinson Name BarNumber Email TimestampSubmitted Status David PatrickJunkin [email protected] 4/21/2025 11:00:55 AM SENT