Trident Homes, Inc. and Ryan Strickland v. Ramesh Kainthla and Neetu Kainthla

ACCEPTED
15-25-00078-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
12/11/2025 12:04 PM
No. 15-25-00078-CV CHRISTOPHER A. PRINE
CLERK
In the Court of Appeals for the FILED IN
15th COURT OF APPEALS
Fifteenth District of Texas at Austin AUSTIN, TEXAS
12/11/2025 12:04:35 PM
CHRISTOPHER A. PRINE
Clerk
Trident Homes, Inc. & Ryan Strickland,
Appellants,
v.
Ramesh Kainthla & Neetu Kainthla,
Appellees.

On Appeal from the 272nd District Court of Brazos County, Texas
Trial Court Cause No. 21-000379-CV-272

Unopposed Motion for Extension of Time to
File the Appellants’ Reply Brief

Chad Flores Matthew D. Sharpe
Texas Bar No. 24059759 Texas Bar No. 24067160
cf@chadflores.law matt.sharpe@lonestarlawoffice.com
Flores Law PLLC Sharpe Law, PC
917 Franklin Street, Suite 600 416 Tarrow St
Houston, Texas 77002 College Station, Texas 77840
(713) 364-6640 (832) 416-1133

Mark Hellinger
Texas Bar. No. 09394975
mhellinger@hellingerlawfirm.com
The Hellinger Law Firm
12 Greenway Plaza, Suite 1100
Houston, TX 77046-1201
(713) 623-1152

Counsel for Appellants
Motion

Appellants file this unopposed motion for an extension of time to file the

appellants’ reply brief. The filing’s present deadline is December 26, 2025.

Appellants request that this filing’s deadline be extended 30 days to make the filing

due on or before January 26, 2026. This is Appellants’ first request for an extension

of this filing’s deadline. This motion is unopposed.

Good cause for this extension exists. Lead appellate counsel has been and

continues to be engaged in other litigation with imminent deadlines that have

prevented him from completing the brief before the present deadline, including:

- Lead counsel representation for Megalomedia Inc. v. Philadelphia Ins. Co. No.
23-20570 in the United States Court of Appeals for the Fifth Circuit, with an
oral argument occurring November 3, 2025.

- Lead counsel representation for Defense Distributed v. YouTube LLC, Google
LLC, and Alphabet, Inc., No. 1.25-cv-01095 in the United States District Court
for the Western District of Texas, with a hearing on a motion to transfer and
motion to remand occurring November 6, 2025.

- Lead counsel representation for Second Street Properties, LLC v. Freeport
Waterfront Properties LP, No. 01-25-00492-CV in the Court of Appeals for the
First District of Texas at Houston, with the appellants’ brief filed November
14, 2025.

- Lead counsel representation for Luedtke v. Brouse., No. 1242514 in the Harris
County Civil Court at Law No. 4, with trial occurring November 18, 2025.

For these reasons, Appellants respectfully request that the Court extend the

deadline for filing of the Appellants’ reply brief to January 26, 2026.

1
Conclusion

The Court should grant the motion’s requested extension and set the filing

deadline for the appellants’ reply brief at January 26, 2026.

Respectfully submitted,

Chad Flores
Texas Bar No. 24059759
cf@chadflores.law
Flores Law PLLC
917 Franklin Street, Suite 600
Houston, Texas 77002
(713) 364-6640

Counsel for Appellants

2
Certificate of Conference

I conferred with Appellees’ counsel about this motion and determined that
Appellees’ do not oppose the requested extension.

/s/ Chad Flores
Chad Flores

Certificate of Compliance

This document contains 283 words counted in accordance with the Texas Rules of
Appellate Procedure.

/s/ Chad Flores
Chad Flores

Certificate of Service

A true and correct copy of this submission was electronically filed and served
on all counsel listed below. See Tex. R. App. P. 9.2(c)(1), 9.5(b)(1).

Joseph R. Knight J. Davis Watson
Texas Bar No. 11601275 Texas Bar No. 24004979
Jknight@ebbklaw.com Dwatson@watsonlawyers.com
Ewell, Brown, Blanke, & Knight LLP Watson Law Firm
111 Congress Ave. Suite 2800 1450 Copperfield Pkwy, Suite 300
Austin, Texas 78701 College Station, Texas 77845
(512) 770-4010 (979) 703-4044

/s/ Chad Flores
Chad Flores

3
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.

Charles Flores on behalf of Charles Flores
Bar No. 24059759
cf@chadflores.law
Envelope ID: 108987770
Filing Code Description: Motion
Filing Description: Unopposed Motion for Extension of Time to File the
Appellants??? Reply Brief
Status as of 12/11/2025 12:13 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Mark Hellinger mhellinger@hellingerlawfirm.com 12/11/2025 12:04:35 PM SENT

Matthew D.Sharpe matt.sharpe@lonestarlawoffice.com 12/11/2025 12:04:35 PM SENT

Charles Flores cf@chadflores.law 12/11/2025 12:04:35 PM SENT

Charles Flores cf@chadflores.law 12/11/2025 12:04:35 PM SENT

J. Davis Watson dwatson@watsonlawyers.com 12/11/2025 12:04:35 PM SENT

Sean Hester shester@watsonlawyers.com 12/11/2025 12:04:35 PM SENT