Mark Smith v. Bank of America, N.A.

15-25-00163-CV ACCEPTED
03-25-00717-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
11/19/2025 11:05 PM
CHRISTOPHER A. PRINE
IN THE FIFTEENTH COURT OF APPEALS CLERK
AUSTIN, TEXAS FILED IN
15th COURT OF APPEALS
No. 03-25-00717-CV AUSTIN, TEXAS
(or 15-25-00717-CV if the clerk has restyled the case) 11/19/2025 11:05:58 PM
CHRISTOPHER A. PRINE
Mark Smith, Appellant Clerk
v.
Bank of America, N.A., Appellee

On Appeal from the 250th Judicial District Court of Travis County, Texas
Trial Court Cause No. D-1-GN-19-003913

APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME
TO FILE OPENING BRIEF

TO THE HONORABLE JUSTICES OF THE FIFTEENTH COURT OF APPEALS:

Appellant Mark Smith respectfully moves for a 30-day extension of time to file his Opening Brief, and in
support shows the following:

1. Current Deadline
The Clerk’s Record and Reporter’s Record were filed on October 22, 2025. Under Texas Rule of
Appellate Procedure 38.6(a), Appellant’s brief is currently due November 24, 2025.

2. Requested Deadline
Appellant requests a 30-day extension, making the new due date December 24, 2025 (or the next
business day if the Court prefers).

3. Good Cause Exists
Good cause supports this request:

• This appeal was administratively transferred from the Third Court of Appeals to the newly
created Fifteenth Court of Appeals, creating procedural uncertainty about docketing and filing
logistics.

• Appellant only recently received confirmation that the record had been fully filed and transferred.

• Additional time is required to finish preparing a complete and organized Opening Brief that fully
addresses the trial court’s Findings of Fact and Conclusions of Law and the legal issues presented.

APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE OPENING BRIEF Page 1 of 2
This request is not made for delay but in the interest of ensuring that Appellant can present a clear and
accurate brief for the Court’s consideration.

4. First Request

This is Appellant’s first request for extension of time to file his Opening Brief.

PRAYER
Appellant respectfully asks the Court to grant a 30-day extension of time to file the Opening Brief,
making the new deadline December 24, 2025, or any date the Court deems appropriate. Appellant seeks
all other relief to which he may be justly entitled.

Respectfully submitted,
/s/ Mark Smith
Mark Smith, Appellant Pro Se
5604 Southwest Parkway, Apt. 3631
Austin, Texas 78735
Email: marksmithinbox@yahoo.com
Phone: 5126604111

CERTIFICATE OF CONFERENCE
Appellant is pro se. Appellee’s position on this motion is unknown.

/s/ Mark Smith
Mark Smith

CERTIFICATE OF SERVICE
I certify that a true and correct copy of this Motion was served on Appellee’s counsel, Tyler Lansden,
Javitch Block LLC, at dal@jbllc.com, on the date of filing via eFileTexas.

/s/ Mark Smith
Mark Smith

APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE OPENING BRIEF Page 2 of 2