Texas Department of Agriculture v. Be a Champion, Inc.; James Hong; Kevin Klotz; George Moon; And Jaron Barganier

ACCEPTED 15-25-00089-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 9/5/2025 10:38 AM No. 15-25-00089-CV CHRISTOPHER A. PRINE CLERK In the Court of Appeals for the Fifteenth Judicial District FILED IN 15th COURT OF APPEALS Austin, Texas AUSTIN, TEXAS 9/5/2025 10:38:46 AM CHRISTOPHER A. PRINE Clerk T EXAS D EPARTMENT OF A GRICULTURE , ET AL ., Appellants, v. B E A C HAMPION , I NC ., J AMES H ONG , K EVIN K LOTZ , G EORGE M OON, AND J ARON B ARGANIER , Appellees.

On Appeal from the 200th Judicial District Court, Travis County APPELLANTS’ MOTION FOR AN EXTENSION

Texas Department of Agriculture, et al. (“Appellants”) seek a seven-day extension of their deadline to file a reply brief. Appellants’ reply brief is currently due on September 15, 2025. With the extension, Appellants’ reply brief would be due on September 22, 2025.

Appellants seek this extension as their counsel was out on August 27th, September 1st, and September 2nd due to office closures and a family vacation. Further, Appellants need additional time to adequately brief the complicated issues raised in this case. Appellees’ counsel advised that they were unopposed to the instant request.

Thus, Appellants respectfully request that the Court extend the deadline to file their reply brief in this case to September 22, 2025. This is Appellants’ first request for an extension of their reply brief.

Date: September 5, 2025 Respectfully Submitted.

KEN PAXTON Attorney General of Texas BRENT WEBSTER First Assistant Attorney General RALPH MOLINA Deputy First Assistant Attorney General AUSTIN KINGHORN Deputy Attorney General for Civil Litigation KIMBERLY GDULA Chief, General Litigation Division /s/ Todd Dickerson TODD DICKERSON Attorney-in-Charge Texas Bar No. 24118368 [email protected] Assistant Attorney General Office of the Attorney General P.O. Box 12548-Capitol Station Austin, Texas 78711-2548 (512) 463-2120 FAX: (512) 320-0667 COUNSEL FOR DEFENDANTS-APPELLANTS

CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing was filed electronically and that notice of this filing will be sent to all counsel who have appeared in this matter through Texas’s electronic filing system on September 5, 2025.

/s/ Todd Dickerson CERTIFICATE OF CONFERENCE On September 3, 2025, I conferred by email with Appellees’ counsel (Kevin Terrazas) about the subject of this motion. Appellees’ counsel advised that they were unopposed to the instant request.

/s/ Todd Dickerson

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.

Thomas Ray on behalf of Todd Dickerson Bar No. 24118368 [email protected] Envelope ID: 105247541 Filing Code Description: Motion Filing Description: Appellants' Motion for Extension Status as of 9/5/2025 10:50 AM CST Associated Case Party: Be a Champion, Inc. Name BarNumber Email TimestampSubmitted Status Kevin Terrazas 24060708 [email protected] 9/5/2025 10:38:46 AM SENT Benjamin Dower 24082931 [email protected] 9/5/2025 10:38:46 AM SENT Jennifer Foster 24104938 [email protected] 9/5/2025 10:38:46 AM SENT

Associated Case Party: Texas Department of Agriculture Name BarNumber Email TimestampSubmitted Status Thomas Ray [email protected] 9/5/2025 10:38:46 AM SENT Todd Dickerson [email protected] 9/5/2025 10:38:46 AM SENT