Dominique Reed and Dakota Hill v. Cypress Creek at South Cedar

ACCEPTED
15-25-00197-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
12/12/2025 3:20 PM
CHRISTOPHER A. PRINE
CLERK

In The FILED IN
15th COURT OF APPEALS
AUSTIN, TEXAS
FIFTEENTH COURT OF APPEALS 12/12/2025 3:20:48 PM
CHRISTOPHER A. PRINE
Clerk

NO. 15-25-00197-CV

DOMINIQUE REED AND DAKOTA HILL Appellants
V.
CYPRESS CREEK AT SOUTH CEDAR Appellee

On Appeal from the County Court at Law No 1
Bell County, Texas
Trial Court Cause No. 25CCV01420

APPELLANT’S EMERGENCY MOTION TO EXTEND TIME TO FILE
APPELLANT’S BRIEF AND, IF NECESSARY, FOR LEAVE TO FILE OUT
OF TIME

TO THE HONORABLE COURT OF APPEALS:

Pursuant to Tex. R. App. P. 10.1, 10.5(b), and 38.6(d), Appellant’s, appearing pro

se, respectfully moves for a 30‑day extension of time to file the appellant’s brief

and, because the deadline has passed, for leave to file out of time. In support,

Appellant states as follows.
I. Deadline and Length of Extension Requested

1.​ The appellant’s brief was due on December 10, 2025.

2.​ Appellant requests a 30‑day extension, through and including January 9,

2026.

II. Reasonable Explanation for the Extension and Late Filing

1.​ On November 19, 2025 the temporary stay that was granted October 29,

2025 was dissolved, and on December 3, 2025 a writ of possession was

served. Appellant and Appellant’s adult daughter (a co‑tenant) lost

possession that day and are currently unhoused, living in their vehicle.

2.​ All belongings, including the appellate case materials, are in storage.

Appellant’s lacked stable access to a computer and Wi‑Fi necessary to

prepare and file the brief. Appellant did not have access to Wi‑Fi and a

computer to file until December 12, 2025.

3.​ Appellant is also self‑represented in a separate post‑divorce receivership

matter ongoing in the 146th District Court, Bell County, Texas with a setting

on January 6, 2026. The two matters have required extensive research and

preparation, and Appellant’s had hoped to avoid overlapping deadlines.

4.​ These circumstances constitute a reasonable explanation for the need for
additional time and for filing this motion two days after the deadline.

III. Prior Extensions and Good Faith

1.​ No prior extensions have been requested or granted for the appellant’s brief.

2.​ This motion is made in good faith and not for purposes of delay. A short

extension will not prejudice Appellee and will assist the Court by allowing

submission of a complete, properly supported brief.

IV. Prayer

For the foregoing reasons, Appellant’s respectfully requests that the Court:

●​ Extend the time to file the appellant’s brief by 30 days, from December 10,

2025, to January 9, 2026; and

●​ To the extent necessary under Tex. R. App. P. 38.6(d), grant leave to file the

brief out of time; and

●​ Grant such other and further relief to which Appellant’s may be justly
entitled.

Respectfully submitted,

/s/Dominique Reed, Pro Se

/s/Dakota Hill, Pro Se​
​
December 11, 2025
Certificate of Conference
I certify that on December 12, 2025, I conferred with counsel for Appellee on this
motion. Appellee is unopposed.

/s/Dominique Reed

/s/Dakota Hill​

Certificate of Service
I certify that on December 12 2025, a true and correct copy of this Motion was
servedonAppellee’sCounsel(barclay@hooverslovacek.com)Joshua
Anderson(anderson@hooverslovacek.com) via eFileTexas.

/s/Dominique Reed

/s/Dakota Hill​
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.

Envelope ID: 109052230
Filing Code Description: Other Brief
Filing Description: APPELLANT???S EMERGENCY MOTION TO
EXTEND TIME TO FILE APPELLANT???S BRIEF AND, IF
NECESSARY, FOR LEA VE TO FILE OUT OF TIME
Status as of 12/12/2025 3:45 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Brooke Broderick broderick@hooverslovacek.com 12/12/2025 3:20:48 PM SENT

Alex Barclay barclay@hooverslovacek.com 12/12/2025 3:20:48 PM SENT

Christy Case manager.ccsc@bonnercarrington.com 12/12/2025 3:20:48 PM SENT

Dominique ACReed dominique.ac.reed@outlook.com 12/12/2025 3:20:48 PM SENT

Joshua Anderson janderson@hooverslovacek.com 12/12/2025 3:20:48 PM ERROR