ACCEPTED 15-25-00078-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 12/11/2025 12:04 PM No. 15-25-00078-CV CHRISTOPHER A. PRINE CLERK In the Court of Appeals for the FILED IN 15th COURT OF APPEALS Fifteenth District of Texas at Austin AUSTIN, TEXAS 12/11/2025 12:04:35 PM CHRISTOPHER A. PRINE Clerk Trident Homes, Inc. & Ryan Strickland, Appellants, v. Ramesh Kainthla & Neetu Kainthla, Appellees.

On Appeal from the 272nd District Court of Brazos County, Texas Trial Court Cause No. 21-000379-CV-272

Unopposed Motion for Extension of Time to File the Appellants’ Reply Brief

Chad Flores Matthew D. Sharpe Texas Bar No. 24059759 Texas Bar No. 24067160 [email protected] [email protected] Flores Law PLLC Sharpe Law, PC Franklin Street, Suite 600 416 Tarrow St Houston, Texas 77002 College Station, Texas 77840 (713) 364-6640 (832) 416-1133 Mark Hellinger Texas Bar. No. 09394975 [email protected] The Hellinger Law Firm Greenway Plaza, Suite 1100 Houston, TX 77046-1201 (713) 623-1152 Counsel for Appellants Motion Appellants file this unopposed motion for an extension of time to file the appellants’ reply brief. The filing’s present deadline is December 26, 2025.

Appellants request that this filing’s deadline be extended 30 days to make the filing due on or before January 26, 2026. This is Appellants’ first request for an extension of this filing’s deadline. This motion is unopposed.

Good cause for this extension exists. Lead appellate counsel has been and continues to be engaged in other litigation with imminent deadlines that have prevented him from completing the brief before the present deadline, including: - Lead counsel representation for Megalomedia Inc. v. Philadelphia Ins. Co. No. 23-20570 in the United States Court of Appeals for the Fifth Circuit, with an oral argument occurring November 3, 2025.

- Lead counsel representation for Defense Distributed v. YouTube LLC, Google LLC, and Alphabet, Inc., No. 1.25-cv-01095 in the United States District Court for the Western District of Texas, with a hearing on a motion to transfer and motion to remand occurring November 6, 2025.

- Lead counsel representation for Second Street Properties, LLC v. Freeport Waterfront Properties LP, No. 01-25-00492-CV in the Court of Appeals for the First District of Texas at Houston, with the appellants’ brief filed November 14, 2025.

- Lead counsel representation for Luedtke v. Brouse., No. 1242514 in the Harris County Civil Court at Law No. 4, with trial occurring November 18, 2025.

For these reasons, Appellants respectfully request that the Court extend the deadline for filing of the Appellants’ reply brief to January 26, 2026.

Conclusion The Court should grant the motion’s requested extension and set the filing deadline for the appellants’ reply brief at January 26, 2026.

Respectfully submitted,

Chad Flores Texas Bar No. 24059759 [email protected] Flores Law PLLC Franklin Street, Suite 600 Houston, Texas 77002 (713) 364-6640 Counsel for Appellants

Certificate of Conference I conferred with Appellees’ counsel about this motion and determined that Appellees’ do not oppose the requested extension.

/s/ Chad Flores Chad Flores Certificate of Compliance This document contains 283 words counted in accordance with the Texas Rules of Appellate Procedure.

/s/ Chad Flores Chad Flores Certificate of Service A true and correct copy of this submission was electronically filed and served on all counsel listed below. See Tex. R. App. P. 9.2(c)(1), 9.5(b)(1).

Joseph R. Knight J. Davis Watson Texas Bar No. 11601275 Texas Bar No. 24004979 [email protected] [email protected] Ewell, Brown, Blanke, & Knight LLP Watson Law Firm Congress Ave. Suite 2800 1450 Copperfield Pkwy, Suite 300 Austin, Texas 78701 College Station, Texas 77845 (512) 770-4010 (979) 703-4044

/s/ Chad Flores Chad Flores

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.

Charles Flores on behalf of Charles Flores Bar No. 24059759 [email protected] Envelope ID: 108987770 Filing Code Description: Motion Filing Description: Unopposed Motion for Extension of Time to File the Appellants??? Reply Brief Status as of 12/11/2025 12:13 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Mark Hellinger [email protected] 12/11/2025 12:04:35 PM SENT Matthew D.Sharpe [email protected] 12/11/2025 12:04:35 PM SENT Charles Flores [email protected] 12/11/2025 12:04:35 PM SENT Charles Flores [email protected] 12/11/2025 12:04:35 PM SENT J. Davis Watson [email protected] 12/11/2025 12:04:35 PM SENT Sean Hester [email protected] 12/11/2025 12:04:35 PM SENT