Texas Education Agency v. Excellence 2000 INC. and Sherwin Allen

ACCEPTED
15-25-00148-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
10/8/2025 3:51 PM
No. 15-25-00148-CV CHRISTOPHER A. PRINE
CLERK
FILED IN
15th COURT OF APPEALS
IN THE COURT OF APPEALS AUSTIN, TEXAS
10/8/2025 3:51:03 PM
FOR THE FIFTEENTH DISTRICT OF T EXAS
CHRISTOPHER A. PRINE
Clerk

TEXAS EDUCATION AGENCY
Appellant
v.

EXCELLENCE 2000 INC.
Appellee

On Appeal from the 125th Judicial District Court
Harris County, Texas
Trial Court Cause No. 2022-55524

EXCELLENCE 2000, INC.’S MOTION FOR EXTENSION
_______________________________________________

Melvin Houston
State Bar No. 00793987
HOUSTON LAW GROUP, PLLC
3033 Chimney Rock, Suite 610
Houston, Texas 77056
(713) 212-0600
(713) 212-0290 (facsimile)
mhouston@gotellmel.com
Attorney for Excellence 2000, Inc.
TO THE HONORABLE JUSTICES OF THE COURT:
Excellence 2000, Inc. respectfully requests a 30-day extension of time to file

its Response under Texas Rules of Appellate Procedure and in support would show

as follows:

1. The Texas Education Agency (‘TEA”) Brief was filed on September 22, 2025.

2. As indicated in the certificate of conference, TEA does not oppose this

extension.

3. The current filing deadline for the Response is October 13, 2025.

4. Excellence 2000, Inc. requests a 30-day extension of the current filing

deadline, which would make the Response due November 13, 2025.

5. Counsel has been reviewing the extensive Brief, the Record and the First

Court of Appeal’s decision. However, despite diligent efforts to complete the

Response, counsel needs additional time to complete the Response because of

concurrent deadlines and requirements in other matters:

• Edmonson v. Turner, Cause No. 2023-002666-3, In the County Court at
Law, Number 3, Tarrant County, Texas
• Sanchez v. Hernandez, Cause No. 01-24-00987-CV; In the First Court of
Appeals, Harris County, Texas
• Carke v. Jereh, Cause No. 2020-68829, In the 61st Judicial District Court,
Harris County, Texas
6. This extension is not sought for the purposes of delay but so that justice may
be done.

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WHEREFORE, Excellence 2000, Inc. respectfully requests the Court grants this

motion and extend the deadline for filing the Response to November 13, 2025.

Respectfully submitted,

/S/ Melvin Houston
Melvin Houston
State Bar No. 00793987
HOUSTON LAW GROUP, PLLC
3033 Chimney Rock, Suite 610
Houston, Texas 77056
(713) 212-0600
(713) 212-0290 (facsimile)
mhouston@gotellmel.com
ATTORNEY FOR APPELEE

CERTIFICATE OF CONFERENCE
I hereby certify that I conferred with opposing counsel on October 8, 2025.
Counsel for Appellant opposes the relief requested in this motion.
/S/ Melvin Houston
Melvin Houston

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CERTIFICATE OF SERVICE

I certify that a true and correct copy of this Motion to Dismiss was served on

the following counsel of record by electronic service on October 8, 2025 to:

JOE NWAOKORO
Assistant Attorney General
Texas Bar No. 24032916
Joe.nwaokoro@oag.texas.gov
Office of the Attorney General
Assistant Attorney General
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
(512) 463-2120 | FAX: (512) 320-0667
Counsel for Appellant

/s/ Melvin Houston
Melvin Houston

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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.

Melvin Houston on behalf of Melvin Houston
Bar No. 793987
mhouston@gotellmel.com
Envelope ID: 106615300
Filing Code Description: Motion
Filing Description: Appellee's Motion for Extension
Status as of 10/8/2025 3:55 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Nikeyla Johnson 24065505 njohnson@contactjohnsonlawfirm.com 10/8/2025 3:51:03 PM SENT

Joe Nwaokoro Joe.Nwaokoro@oag.texas.gov 10/8/2025 3:51:03 PM SENT

Mary Sifuentes Mary.Sifuentes@oag.texas.gov 10/8/2025 3:51:03 PM SENT

Melvin Houston 793987 mhouston@gotellmel.com 10/8/2025 3:51:03 PM SENT