Charles Wagner v. Lamar University, Lamar University Police Department and Hector Flores

ACCEPTED 15-25-00147-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS No. 15-25-00147-CV 10/7/2025 8:45 AM CHRISTOPHER A. PRINE IN THE FIFTHTEENTH COURT OF APPEALS CLERK AUSTIN, TEXAS FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS CHARLES WAGNER, 10/7/2025 8:45:40 AM PLAINTIFF - APPELLANT CHRISTOPHER A. PRINE Clerk V. LAMAR UNIVERSITY, LAMAR UNIVERSITY POLICE DEPARTMENT, AND HECTOR FLORES, DEFENDANTS – APPELLEES ON APPEAL FROM THE 136TH JUDICIAL DISTRICT COURT, JEFFERSON COUNTY CAUSE NO. 23DCCV0870

APPELLANT’S UNOPPOSED REQUEST FOR ADDITIONAL TIME TO FILE APPELLANT’S BRIEF

SUBMITTED BY:

Brandon P. Monk 4875 Parker Drive Beaumont, Texas 77705 Phone: (409) 724-6665 Fax: (409) 729-6665 [email protected] By: /s/ Brandon P. Monk BRANDON P. MONK State Bar No. 24048668

Larry Watts State Bar No. 20981000 P.O. Box 2214 Missouri City, Texas 77459 Ph. (281) 431-1500 [email protected] ATTORNEYS FOR APPELLANT

CERTIFICATE OF INTERESTED PERSONS The undersigned counsel of record certifies that the following listed persons and entities have an interest in the outcome of this case. These representations are made in order that the judges of this court may evaluate possible disqualification or recusal.

Appellees: Counsel for Appellees: LAMAR UNIVERSITY JOSEPH KEENEY Assistant Attorney General Texas Bar No. 24092616 Office of the Attorney General General Litigation Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Telephone (512) 475-4090 Facsimile: (512) 320-0667 [email protected] LAMAR UNIVERSITY POLICE JOSEPH KEENEY DEPARTMENT Assistant Attorney General Texas Bar No. 24092616 Office of the Attorney General General Litigation Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Telephone (512) 475-4090 Facsimile: (512) 320-0667 [email protected] HECTOR FLORES JOSEPH KEENEY Assistant Attorney General Texas Bar No. 24092616 Office of the Attorney General General Litigation Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Telephone (512) 475-4090 Facsimile: (512) 320-0667 [email protected] Facsimile: (713) 583-9611 APPELLANT CHARLES WAGNER Brandon Monk State Bar No. 24048668 The Monk Law Firm 4875 Parker Drive Beaumont, Texas 77705 T: 409/724-6665 F: 409/729-6665 [email protected] Larry Watts State Bar No. 20981000 P.O. Box 2214 Missouri City, Texas 77459 Ph. (281) 431-1500 [email protected]

CHARLES WAGNER’S MOTION FOR EXTENSION OF TIME TO FILE TO THE HONORABLE COURT OF APPEALS: COMES NOW Appellant, CHARLES WAGNER (“Appellant”) and files this Unopposed Motion for Extension of Time to File their Brief.

BASIS FOR REQUEST FOR EXTENSION

3|Page 1. The current deadline for Appellant to file their Brief is October 9, 2025.

The Appellant respectfully request an additional thirty (30) days to file his Brief.

This is Appellant’s first request for additional time.

2. Appellant’s counsel would further show that the extension is necessary as a result of scheduling conflicts detailed in this Motion. The following are deadlines and events that were during the timeframe of the response and relevant to the Court’s consideration of this Motion: • 09/10/2025 –09/22/2025 - Out of Office • 09/23/2025 – Case No. 9-24-cv-00221 - Torres v. City of Ivanhoe Hearing • 09/29/2025 – Deposition – Escobedo for Maida v. Hamilton Homebuilers, et al • 09/30/2025 – Case No. 23DCCV1820 Myers v. Lion Elastomers – Mediation • 10/2/2025 - Cause No. D-208,503; Martin, et al v. Meza – Mediation • 10/8/2025 – 24-40704 Murphy v. Beaumont ISD – Oral Argument 5th Circuit Court of Appeal in New Orleans (out for travel) • 10/9/2025 – 24-40704 Murphy v. Beaumont ISD – Oral Argument 5th Circuit Court of Appeal in New Orleans

4|Page 3. Appellant has conferred with counsel for the Appellees, LAMAR UNIVERSITY, LAMAR UNIVERSITY POLICE DEPARTMENT, AND HECTOR FLORES, and Appellees do not object to an additional thirty (30) day extension, which will make the deadline to file Appellant’s Brief due on or before Monday, November 10, 2025.

4. Appellant would further show the Court that this request for an extension is not brought for the purpose of delay.

SUBMITTED BY:

Brandon P. Monk 4875 Parker Drive Beaumont, Texas 77705 Phone: (409) 724-6665 Fax: (409) 729-6665 [email protected] By: /s/ Brandon P. Monk BRANDON P. MONK State Bar No. 24048668 Larry Watts State Bar No. 20981000 P.O. Box 2214 Missouri City, Texas 77459 Ph. (281) 431-1500 [email protected] ATTORNEYS FOR APPELLANT

5|Page CERTIFICATE OF CONFERENCE On October 7, 2025, counsel for Appellant was contacted via email regarding whether the Appellees opposed Appellant’s Request for Additional Time, and counsel for Appellees were not opposed.

By: /s/Brandon P. Monk Brandon P. Monk CERTIFICATE OF SERVICE I certify that on October 7, 2025, the foregoing document was forwarded via the electronic filing system to all counsel of record:

/s/Brandon P. Monk Brandon P. Monk

6|Page 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.

Ednesha Cook on behalf of Brandon Monk Bar No. 24048668 [email protected] Envelope ID: 106523956 Filing Code Description: Motion Filing Description: Appellant's Motion to Extend Time to file Brief Status as of 10/7/2025 9:43 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Andrew Harris 24057887 [email protected] 10/7/2025 8:45:40 AM NOT SENT Jennifer Holt [email protected] 10/7/2025 8:45:40 AM NOT SENT Joseph Keeney 24092616 [email protected] 10/7/2025 8:45:40 AM NOT SENT Brandon P.Monk [email protected] 10/7/2025 8:45:40 AM NOT SENT Larry Watts [email protected] 10/7/2025 8:45:40 AM NOT SENT