Brian Beckcom v. Texas A&M University

Opinion

ACCEPTED 15-25-00124-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 11/10/2025 9:35 PM Cause No. 15-25-00124-CV CHRISTOPHER A. PRINE CLERK Brian Beckcom § FILED IN 15th COURT OF APPEALS § Court of Appeals ofAUSTIN, TexasTEXAS v. § 11/10/2025 9:35:12 PM § Fifteenth District CHRISTOPHER A. PRINE Clerk Texas A&M University §

Appellant’s Motion to Extend Deadline to File Appellant’s Brief and Appendix

Appellant Brian Beckcom respectfully requests this Court to extend

his deadline to file his opening brief until November 17, 2025 for the

following reasons:

1. On October 9, 2025, this Court denied Appellant’s motion to

abate and ordered Appellant to file his opening brief and appendix by

November 10, 2025.

2. Appellant elected to prepare an appendix in lieu of a clerk’s

record in this appeal because Appellee filed more than 3,000 pages of

documents in the district court proceeding, which would have made a formal

clerk’s record exorbitantly expensive.

3. Due to an inadvertent error when paginating the Appendix,

Appellant’s undersigned counsel is required to renumber it—as well as all of

the record references in his brief.

-1- 4. Appellant’s undersigned counsel has been delayed in the

preparation of the Appendix because, in the 30 days since this Court set the

deadline for Appellant’s brief, he has also been responsible for the following

matters:

¾ October 13, 2025: Reply brief due in Strauss v. Texas Department of Criminal Justice, which is pending in this Court as Case No. 15-25-00079-CV;

¾ October 13 and 20, 2025: Hearing on motions for new trial and motions for sanctions in Snow v. Let’s Go on Vacay, LLC, which is pending in the 17th District Court of Tarrant County, Texas as Case No. 017-334326-22;

¾ October 16, 2025: Opposition to motion for summary judgment due in Doe v. Roe, which is pending in California’s Superior Court for Sacramento County as Case No. 34-2022-00330787;

¾ October 23, 2025: Motion for new trial due in Shefer v. Glazer, which is pending in California’s Supreme Court for Los Angeles County as Case No. 19STCV26940;

¾ October 24, 2025: Response to post-hearing briefing due in Morales v. Extra Space Management, Inc., which is pending in private arbitration with Mark Gilbert in Dallas, Texas;

¾ October 31, 2025: Response to motion for summary judgment due in Depalma v. GMZ Trucking, LLC, which is pending in the 362nd District Court of Denton County, Texas as Cause No. 24-10905-158;

¾ November 3, 2025: Oral argument in Tunkle v. Reliastar Life Insurance Co., which is pending in the United States Court of Appeals for the Eleventh Circuit as Case No. 24-12563;

-2- ¾ November 4, 2025: Oral argument in City of San Antonio v. Realme, which is pending in the Supreme Court of Texas in, as Case No. 24-0864;

¾ November 12, 2025: Reply brief due in Bencomo v. Embrey Management Services, which is pending in Texas’s Eleventh Court of Appeals as Case No. 11-25-00152-CV;

¾ November 13, 2025: Oral argument in Weathers v. Campbell Energy & Environmental Services, which is pending in Texas’s Twelfth Court of Appeals as Case No. 12-25-00045-CV.

4. Appellant’s undersigned counsel is a solo practitioner, who has

prepared all of the above-referenced filings (and prepared for all of the

above-referenced hearings) without the assistance of other attorneys or

administrative staff.

5. Accordingly, Appellant’s undersigned counsel respectfully

requests an additional seven days to file Appellant’s brief and appendix.

6. If granted, Appellant’s brief and appendix would be due on

November 17, 2025.

7. This is Appellant’s first request for an extension to file his

opening brief.

8. This motion is not made for purposes of delay and Appellee will

not be prejudiced if this motion is granted.

-3- Respectfully submitted,

/s/ Matthew J. Kita Matthew J. Kita Texas Bar No. 24050883 3110 Webb Avenue, Suite 150 Dallas, Texas 75205 (214) 699-1863 matt@mattkita.com

Counsel for Appellant

Certificate of Conference

I certify that on November 10, 2025, I emailed Appellee’s counsel, Jason Contreras, to inform him that I would be asking this Court for the relief addressed above. Because I did not discover this issue until after business hours today, I have not yet received a response. Accordingly, it is submitted to this Court for consideration with the presumption that it will be opposed. Should Mr. Contreras inform me otherwise, I will inform this Court as soon as I am able.

/s/ Matthew J. Kita Matthew J. Kita

Certificate of Service

I certify that on November 10, 2025, I served a copy of this motion on all counsel of record via e-filing in accordance with Texas Rule of Appellate Procedure 9 and this Court’s local rules.

-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.

Matthew Kita on behalf of Matthew Kita Bar No. 24050883 matt@mattkita.com Envelope ID: 107891973 Filing Code Description: Motion Filing Description: Appellant???s Motion to Extend Deadline to File Appellant???s Brief and Appendix Status as of 11/12/2025 7:26 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Matthew J.Kita matt@mattkita.com 11/10/2025 9:35:12 PM SENT

Jason T.Contreras jason.contreras@oag.texas.gov 11/10/2025 9:35:12 PM SENT