Texas Department of Agriculture v. Be a Champion, Inc.; James Hong; Kevin Klotz; George Moon; And Jaron Barganier

ACCEPTED
15-25-00089-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
9/5/2025 10:38 AM
No. 15-25-00089-CV CHRISTOPHER A. PRINE
CLERK

In the Court of Appeals for the Fifteenth Judicial District
FILED IN
15th COURT OF APPEALS

Austin, Texas
AUSTIN, TEXAS
9/5/2025 10:38:46 AM
CHRISTOPHER A. PRINE
Clerk
T EXAS D EPARTMENT OF A GRICULTURE , ET AL .,
Appellants,
v.
B E A C HAMPION , I NC ., J AMES H ONG , K EVIN K LOTZ ,
G EORGE M OON, AND J ARON B ARGANIER ,
Appellees.

On Appeal from the
200th Judicial District Court, Travis County

APPELLANTS’ MOTION FOR AN EXTENSION

Texas Department of Agriculture, et al. (“Appellants”) seek a seven-day

extension of their deadline to file a reply brief. Appellants’ reply brief is currently due

on September 15, 2025. With the extension, Appellants’ reply brief would be due on

September 22, 2025.

Appellants seek this extension as their counsel was out on August 27th,

September 1st, and September 2nd due to office closures and a family vacation. Further,

Appellants need additional time to adequately brief the complicated issues raised in this

case. Appellees’ counsel advised that they were unopposed to the instant request.
Thus, Appellants respectfully request that the Court extend the deadline to file

their reply brief in this case to September 22, 2025. This is Appellants’ first request for

an extension of their reply brief.

Date: September 5, 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/ Todd Dickerson
TODD DICKERSON
Attorney-in-Charge
Texas Bar No. 24118368
Todd.Dickerson@oag.texas.gov
Assistant Attorney General
Office of the Attorney General
P.O. Box 12548-Capitol Station
Austin, Texas 78711-2548
(512) 463-2120
FAX: (512) 320-0667
COUNSEL FOR DEFENDANTS-APPELLANTS

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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 all counsel who have appeared in this matter

through Texas’s electronic filing system on September 5, 2025.

/s/ Todd Dickerson

CERTIFICATE OF CONFERENCE

On September 3, 2025, I conferred by email with Appellees’ counsel (Kevin

Terrazas) about the subject of this motion. Appellees’ counsel advised that they were

unopposed to the instant request.

/s/ Todd Dickerson

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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 Todd Dickerson
Bar No. 24118368
thomas.ray@oag.texas.gov
Envelope ID: 105247541
Filing Code Description: Motion
Filing Description: Appellants' Motion for Extension
Status as of 9/5/2025 10:50 AM CST

Associated Case Party: Be a Champion, Inc.

Name BarNumber Email TimestampSubmitted Status

Kevin Terrazas 24060708 kterrazas@terrazaspllc.com 9/5/2025 10:38:46 AM SENT

Benjamin Dower 24082931 bdower@terrazaspllc.com 9/5/2025 10:38:46 AM SENT

Jennifer Foster 24104938 jfoster@terrazaspllc.com 9/5/2025 10:38:46 AM SENT

Associated Case Party: Texas Department of Agriculture

Name BarNumber Email TimestampSubmitted Status

Thomas Ray thomas.ray@oag.texas.gov 9/5/2025 10:38:46 AM SENT

Todd Dickerson todd.dickerson@oag.texas.gov 9/5/2025 10:38:46 AM SENT