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

Court of Appeals of Texas

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

DecidedOctober 7, 2025

Docket15-25-00147-CV

StatusPublished

This text of Charles Wagner v. Lamar University, Lamar University Police Department and Hector Flores (Charles Wagner v. Lamar University, Lamar University Police Department and Hector Flores) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Charles Wagner v. Lamar University, Lamar University Police Department and Hector Flores, (Tex. Ct. App. 2025).

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Opinion

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 brandon@themonklawfirm.com

By: /s/ Brandon P. Monk BRANDON P. MONK State Bar No. 24048668

1 Larry Watts State Bar No. 20981000 P.O. Box 2214 Missouri City, Texas 77459 Ph. (281) 431-1500 Wattstrial@gmail.com

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 joseph.keeney@oag.texas.gov 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 joseph.keeney@oag.texas.gov 2 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 joseph.keeney@oag.texas.gov 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 brandon@themonklawfirm.com

Larry Watts State Bar No. 20981000 P.O. Box 2214 Missouri City, Texas 77459 Ph. (281) 431-1500 Wattstrial@gmail.com

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.

Brandon P. Monk 4875 Parker Drive Beaumont, Texas 77705 Phone: (409) 724-6665 Fax: (409) 729-6665 brandon@themonklawfirm.com

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 Wattstrial@gmail.com

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 ecook@themonklawfirm.com 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 Drew.Harris@oag.texas.gov 10/7/2025 8:45:40 AM NOT SENT

Jennifer Holt jennifer.holt@oag.texas.gov 10/7/2025 8:45:40 AM NOT SENT

Joseph Keeney 24092616 joseph.keeney@oag.texas.gov 10/7/2025 8:45:40 AM NOT SENT

Brandon P.Monk brandon@themonklawfirm.com 10/7/2025 8:45:40 AM NOT SENT

Larry Watts wattstrial@gmail.com 10/7/2025 8:45:40 AM NOT SENT

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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 brandon@themonklawfirm.com

By: /s/ Brandon P. Monk BRANDON P. MONK State Bar No. 24048668

1 Larry Watts State Bar No. 20981000 P.O. Box 2214 Missouri City, Texas 77459 Ph. (281) 431-1500 Wattstrial@gmail.com

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 joseph.keeney@oag.texas.gov 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 joseph.keeney@oag.texas.gov 2 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 joseph.keeney@oag.texas.gov 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 brandon@themonklawfirm.com

Larry Watts State Bar No. 20981000 P.O. Box 2214 Missouri City, Texas 77459 Ph. (281) 431-1500 Wattstrial@gmail.com

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.

Brandon P. Monk 4875 Parker Drive Beaumont, Texas 77705 Phone: (409) 724-6665 Fax: (409) 729-6665 brandon@themonklawfirm.com

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 Wattstrial@gmail.com

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 ecook@themonklawfirm.com 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 Drew.Harris@oag.texas.gov 10/7/2025 8:45:40 AM NOT SENT

Jennifer Holt jennifer.holt@oag.texas.gov 10/7/2025 8:45:40 AM NOT SENT

Joseph Keeney 24092616 joseph.keeney@oag.texas.gov 10/7/2025 8:45:40 AM NOT SENT

Brandon P.Monk brandon@themonklawfirm.com 10/7/2025 8:45:40 AM NOT SENT

Larry Watts wattstrial@gmail.com 10/7/2025 8:45:40 AM NOT SENT

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Bluebook (online)

Charles Wagner v. Lamar University, Lamar University Police Department and Hector Flores, Counsel Stack Legal Research, https://law.counselstack.com/opinion/charles-wagner-v-lamar-university-lamar-university-police-department-and-texapp-2025.