Texas Education Agency v. Excellence 2000 INC. and Sherwin Allen

ACCEPTED 15-25-00148-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 10/8/2025 3:51 PM No. 15-25-00148-CV CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS IN THE COURT OF APPEALS AUSTIN, TEXAS 10/8/2025 3:51:03 PM FOR THE FIFTEENTH DISTRICT OF T EXAS CHRISTOPHER A. PRINE Clerk

TEXAS EDUCATION AGENCY Appellant v. EXCELLENCE 2000 INC. Appellee

On Appeal from the 125th Judicial District Court Harris County, Texas Trial Court Cause No. 2022-55524

EXCELLENCE 2000, INC.’S MOTION FOR EXTENSION _______________________________________________ Melvin Houston State Bar No. 00793987 HOUSTON LAW GROUP, PLLC 3033 Chimney Rock, Suite 610 Houston, Texas 77056 (713) 212-0600 (713) 212-0290 (facsimile) [email protected] Attorney for Excellence 2000, Inc. TO THE HONORABLE JUSTICES OF THE COURT: Excellence 2000, Inc. respectfully requests a 30-day extension of time to file its Response under Texas Rules of Appellate Procedure and in support would show as follows: 1. The Texas Education Agency (‘TEA”) Brief was filed on September 22, 2025.

2. As indicated in the certificate of conference, TEA does not oppose this extension.

3. The current filing deadline for the Response is October 13, 2025.

4. Excellence 2000, Inc. requests a 30-day extension of the current filing deadline, which would make the Response due November 13, 2025.

5. Counsel has been reviewing the extensive Brief, the Record and the First Court of Appeal’s decision. However, despite diligent efforts to complete the Response, counsel needs additional time to complete the Response because of concurrent deadlines and requirements in other matters: • Edmonson v. Turner, Cause No. 2023-002666-3, In the County Court at Law, Number 3, Tarrant County, Texas • Sanchez v. Hernandez, Cause No. 01-24-00987-CV; In the First Court of Appeals, Harris County, Texas • Carke v. Jereh, Cause No. 2020-68829, In the 61st Judicial District Court, Harris County, Texas 6. This extension is not sought for the purposes of delay but so that justice may be done.

WHEREFORE, Excellence 2000, Inc. respectfully requests the Court grants this motion and extend the deadline for filing the Response to November 13, 2025.

Respectfully submitted, /S/ Melvin Houston Melvin Houston State Bar No. 00793987 HOUSTON LAW GROUP, PLLC 3033 Chimney Rock, Suite 610 Houston, Texas 77056 (713) 212-0600 (713) 212-0290 (facsimile) [email protected] ATTORNEY FOR APPELEE

CERTIFICATE OF CONFERENCE I hereby certify that I conferred with opposing counsel on October 8, 2025.

Counsel for Appellant opposes the relief requested in this motion. /S/ Melvin Houston Melvin Houston

CERTIFICATE OF SERVICE I certify that a true and correct copy of this Motion to Dismiss was served on the following counsel of record by electronic service on October 8, 2025 to: JOE NWAOKORO Assistant Attorney General Texas Bar No. 24032916 [email protected] Office of the Attorney General Assistant Attorney General P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 (512) 463-2120 | FAX: (512) 320-0667 Counsel for Appellant

/s/ Melvin Houston Melvin Houston

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.

Melvin Houston on behalf of Melvin Houston Bar No. 793987 [email protected] Envelope ID: 106615300 Filing Code Description: Motion Filing Description: Appellee's Motion for Extension Status as of 10/8/2025 3:55 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Nikeyla Johnson 24065505 [email protected] 10/8/2025 3:51:03 PM SENT Joe Nwaokoro [email protected] 10/8/2025 3:51:03 PM SENT Mary Sifuentes [email protected] 10/8/2025 3:51:03 PM SENT Melvin Houston 793987 [email protected] 10/8/2025 3:51:03 PM SENT