Brian Beckcom v. Texas A&M University

ACCEPTED
15-25-00124-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
11/10/2025 9:35 PM
Cause No. 15-25-00124-CV CHRISTOPHER A. PRINE
CLERK
Brian Beckcom § FILED IN
15th COURT OF APPEALS
§ Court of Appeals ofAUSTIN,
TexasTEXAS
v. § 11/10/2025 9:35:12 PM
§ Fifteenth District
CHRISTOPHER A. PRINE
Clerk
Texas A&M University §

Appellant’s Motion to Extend Deadline
to File Appellant’s Brief and Appendix

Appellant Brian Beckcom respectfully requests this Court to extend

his deadline to file his opening brief until November 17, 2025 for the

following reasons:

1. On October 9, 2025, this Court denied Appellant’s motion to

abate and ordered Appellant to file his opening brief and appendix by

November 10, 2025.

2. Appellant elected to prepare an appendix in lieu of a clerk’s

record in this appeal because Appellee filed more than 3,000 pages of

documents in the district court proceeding, which would have made a formal

clerk’s record exorbitantly expensive.

3. Due to an inadvertent error when paginating the Appendix,

Appellant’s undersigned counsel is required to renumber it—as well as all of

the record references in his brief.

-1-
4. Appellant’s undersigned counsel has been delayed in the

preparation of the Appendix because, in the 30 days since this Court set the

deadline for Appellant’s brief, he has also been responsible for the following

matters:

¾ October 13, 2025: Reply brief due in Strauss v. Texas Department
of Criminal Justice, which is pending in this Court as Case No.
15-25-00079-CV;

¾ October 13 and 20, 2025: Hearing on motions for new trial and
motions for sanctions in Snow v. Let’s Go on Vacay, LLC, which
is pending in the 17th District Court of Tarrant County, Texas
as Case No. 017-334326-22;

¾ October 16, 2025: Opposition to motion for summary judgment
due in Doe v. Roe, which is pending in California’s Superior
Court for Sacramento County as Case No. 34-2022-00330787;

¾ October 23, 2025: Motion for new trial due in Shefer v. Glazer,
which is pending in California’s Supreme Court for Los Angeles
County as Case No. 19STCV26940;

¾ October 24, 2025: Response to post-hearing briefing due in
Morales v. Extra Space Management, Inc., which is pending in
private arbitration with Mark Gilbert in Dallas, Texas;

¾ October 31, 2025: Response to motion for summary judgment
due in Depalma v. GMZ Trucking, LLC, which is pending in the
362nd District Court of Denton County, Texas as Cause No.
24-10905-158;

¾ November 3, 2025: Oral argument in Tunkle v. Reliastar Life
Insurance Co., which is pending in the United States Court of
Appeals for the Eleventh Circuit as Case No. 24-12563;

-2-
¾ November 4, 2025: Oral argument in City of San Antonio v.
Realme, which is pending in the Supreme Court of Texas in, as
Case No. 24-0864;

¾ November 12, 2025: Reply brief due in Bencomo v. Embrey
Management Services, which is pending in Texas’s Eleventh
Court of Appeals as Case No. 11-25-00152-CV;

¾ November 13, 2025: Oral argument in Weathers v. Campbell
Energy & Environmental Services, which is pending in Texas’s
Twelfth Court of Appeals as Case No. 12-25-00045-CV.

4. Appellant’s undersigned counsel is a solo practitioner, who has

prepared all of the above-referenced filings (and prepared for all of the

above-referenced hearings) without the assistance of other attorneys or

administrative staff.

5. Accordingly, Appellant’s undersigned counsel respectfully

requests an additional seven days to file Appellant’s brief and appendix.

6. If granted, Appellant’s brief and appendix would be due on

November 17, 2025.

7. This is Appellant’s first request for an extension to file his

opening brief.

8. This motion is not made for purposes of delay and Appellee will

not be prejudiced if this motion is granted.

-3-
Respectfully submitted,

/s/ Matthew J. Kita
Matthew J. Kita
Texas Bar No. 24050883
3110 Webb Avenue, Suite 150
Dallas, Texas 75205
(214) 699-1863
matt@mattkita.com

Counsel for Appellant

Certificate of Conference

I certify that on November 10, 2025, I emailed Appellee’s counsel,
Jason Contreras, to inform him that I would be asking this Court for the
relief addressed above. Because I did not discover this issue until after
business hours today, I have not yet received a response. Accordingly, it is
submitted to this Court for consideration with the presumption that it will be
opposed. Should Mr. Contreras inform me otherwise, I will inform this
Court as soon as I am able.

/s/ Matthew J. Kita
Matthew J. Kita

Certificate of Service

I certify that on November 10, 2025, I served a copy of this motion on
all counsel of record via e-filing in accordance with Texas Rule of Appellate
Procedure 9 and this Court’s local rules.

/s/ Matthew J. Kita
Matthew J. Kita

-4-
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.

Matthew Kita on behalf of Matthew Kita
Bar No. 24050883
matt@mattkita.com
Envelope ID: 107891973
Filing Code Description: Motion
Filing Description: Appellant???s Motion to Extend Deadline to File
Appellant???s Brief and Appendix
Status as of 11/12/2025 7:26 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Matthew J.Kita matt@mattkita.com 11/10/2025 9:35:12 PM SENT

Jason T.Contreras jason.contreras@oag.texas.gov 11/10/2025 9:35:12 PM SENT