ACCEPTED 15-25-00147-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 12/8/2025 3:55 PM CHRISTOPHER A. PRINE CLERK No. 15-25-00147-CV FILED IN __________________________________15th COURT OF APPEALS AUSTIN, TEXAS 12/8/2025 3:55:16 PM In the Court of Appeals CHRISTOPHER A. PRINE Clerk for the Fifteenth Judicial District Austin, Texas __________________________________ CHARLES WAGNER, Plaintiff-Appellant, v. LAMAR UNIVERSITY, LAMAR UNIVERSITY POLICE DEPARTMENT, and HECTOR FLORES, Defendants-Appellees. ___________________________________ On Appeal from the 136th Judicial District Court of Jefferson County, Texas ______________________________ APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEE BRIEF ______________________________ TO THE HONORABLE FIFTEENTH COURT OF APPEALS: Appellees Lamar University, Lamar University Police Department, and Hector Flores request a 45-day extension of time for filing their appellee brief in this appeal.

1. The deadline for the appellee brief in this case is currently December 10, 2025.

-1- 2. Appellees request a 45-day extension of time for filing their appellee brief, which would make the effective deadline January 26, 2026 (since 45- days would fall on a Saturday).

3. A motion to extend the time to file a brief may be filed on or after the date a brief is due. See TEX. R. APP. P. 38.6(d). Pursuant to Texas Rule of Appellate Procedure 10.5(b)(1), such motion must contain “(A) the deadline for filing the item in question; (B) the length of the extension sought; (C) the facts relied on to reasonably explain the need for an extension; and (D) the number of previous extensions granted regarding the item in question.”

4. Good cause exists for allowing Appellees an extension of time to file its opening brief. Appellees’ lead counsel is out of the office on paternity leave.

Appellees’ other briefing counsel, the undersigned attorney, contracted COVID in mid-November and required time to recuperate. In addition, the undersigned counsel has invested significant time preparing for federal jury trial scheduled to begin January 13, 2026, in the case McPherson et al. v. Texas Department of Public Safety, No. 1:20-cv-1223; in the U.S. District Court for the Western District of Texas.

-2- 5. This is Appellees’ first request for an extension in this case. This request is sought, not for purposes of delay, but so that proper briefing of this case may be presented to the Court and so that justice may be done.

6. On December 8, 2025, the undersigned counsel conferred with counsel for Appellant, who stated that he is unopposed to the requested extension.

Date: December 8, 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/ Drew L. Harris_______ JOSEPH KEENEY Texas Bar No. 24092616 DREW L. HARRIS Texas Bar No. 24057887 Assistant Attorneys General Office of the Attorney General P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Phone: 737-228-8812 Fax: 512-320-0667 [email protected] -3- [email protected] Attorneys for Appellees

CERTIFICATE OF CONFERENCE I certify that on December 8, 2025, I conferred by email with Brandon Monk, counsel for Appellant, who stated that he is unopposed to the requested 45-day extension. /s/ Drew L. Harris DREW L. HARRIS

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 the following persons through File & Serve Texas’s electronic filing system on December 8, 2025: Brandon P. Monk The Monk Law Firm 4875 Parker Drive Beaumont, Texas 77705 Phone: (409) 724-6665 [email protected] Larry Watts P.O. Box 2214 Missouri City, Texas 77459 Ph. (281) 431-1500 [email protected] Attorneys for Plaintiff /s/ Drew L. Harris DREW L. HARRIS -4- 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 Drew Harris Bar No. 24057887 [email protected] Envelope ID: 108850689 Filing Code Description: Motion Filing Description: Appellees' Unopposed Motion for Extension of Time to File Appellee Brief Status as of 12/8/2025 4:40 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Andrew Harris 24057887 [email protected] 12/8/2025 3:55:16 PM SENT Joseph Keeney 24092616 [email protected] 12/8/2025 3:55:16 PM SENT Thomas Ray [email protected] 12/8/2025 3:55:16 PM SENT Larry Watts [email protected] 12/8/2025 3:55:16 PM SENT Brandon P.Monk [email protected] 12/8/2025 3:55:16 PM SENT Jennifer Holt [email protected] 12/8/2025 3:55:16 PM SENT

Associated Case Party: CharlesWagner Name BarNumber Email TimestampSubmitted Status Heather Johnson [email protected] 12/8/2025 3:55:16 PM SENT