Chase Tutor v. Douglass McLain

ACCEPTED 15-25-00175-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 11/20/2025 10:58 AM No. 03-25-00749-CV CHRISTOPHER A. PRINE CLERK (Transferred to the Fifteenth Court of Appeals) FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS 11/20/2025 10:58:36 AM IN THE CHRISTOPHER A. PRINE Clerk FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS

CHASE TUTOR Appellant, v. DOUGLASS MCLAIN Appellee,

APPELLANT CHASE TUTOR’S MOTION TO EXTEND TIME FOR FILING APPELLANT’S BRIEF

TO THE HONORABLE COURT OF APPEALS: Appellant Chase Tutor (“Appellant”) files this Motion to Extend Time to File Appellant’s Brief and, in support, respectfully states the following: 1. The Court has authority under Texas Rule of Appellate Procedure 38.6(d) to extend the time to file a brief.

2. Appellant’s Brief was first due to be filed with this court on November 21, 2025—i.e., the next day from 30 days after the clerk’s or reporter’s record is filed, which ever is later, that is not a Saturday, Sunday, or legal holiday. (See TEX. R. APP. P. 38.6(a)).

3. Appellant seeks a 30-day extension of time to file Appellant’s Brief, which would make Appellant’s Brief due on or before December 22, 2025.

4. Good cause exists for this extension. Counsel for Appellant has been required to devote substantial time to multiple hearings, motion practice, and briefing deadlines in other trial and appellate matters during the period leading up to Appellant’s current briefing deadline. These obligations have made it difficult to complete Appellant’s brief with the level of accuracy, citation, and depth that the issues warrant. Additional time is needed to ensure complete and accurate presentation of the appellate arguments.

5. This is Appellant’s first request for an extension of time to file his brief.

6. Counsel for Appellant has conferred with counsel for Appellee Douglass McLain (“Appellee”) and Appellee does not oppose this motion to extend time.

PRAYER For these reasons, Appellant Chase Tutor requests that this Court render an order extending the time for filing Appellant’s Brief to and including December 22, 2025. Appellant also requests any other relief to which he may be entitled.

Respectfully submitted,

Russell Frost Texas Bar No. 24063687 Law Office of Russell Frost, PLLC W 7th Street Austin, Texas 78701 Phone: (512) 225-5590 Fax: (512) 692-2895 [email protected] ATTORNEYS FOR APPELLANT CHASE TUTOR CERTIFICATE OF CONFERENCE This certifies that the undersigned counsel for Appellant Chase Tutor conferred with Counsel for Appellee Douglas McLain regarding the merits of this motion, and Appellee does not oppose this motion.

Russell Frost CERTIFICATE OF SERVICE I hereby certify that the above and foregoing document has been served upon the following in accordance with the Texas Rules of Civil Procedure on this the 20th day of November 2025.

Russell Frost