Medhat S.F. Michael, M.D. v. Texas Medical Board

ACCEPTED
15-25-00181-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
12/23/2025 1:18 PM
No. 15-25-00181-CV CHRISTOPHER A. PRINE
CLERK

In the Fifteenth Court of Appeals FILED IN
15th COURT OF APPEALS
AUSTIN, TEXAS
Austin, Texas 12/23/2025 1:18:47 PM
CHRISTOPHER A. PRINE
Clerk

Medhat S.F. Michael, M.D.,

Appellant

V.

Texas Medical Board,

Appellee

Appeal from 201st Judicial District Court, Travis County, Texas
Trial Court Cause No. D-1-GN-17-002146
Hon. Amy Clark Meachum, Judge Presiding

THIRD MOTION FOR EXTENSION
OF TIME TO FILE APPELLANT’S BRIEF

TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

Appellant Medhat S.F. Michael, M.D. requests a thirty-day

extension of time for filing his brief.

1. The record was filed on September 25, 2025. Appellant’s brief

is due December 29, 2025. This is Appellant’s third request for an

extension of time to file his brief.
2. The undersigned counsel was not involved in the underlying

proceedings. Counsel needs sufficient time to review the appellate and

administrative records and prepare a brief that will help the Court

resolve this appeal.

3. The demands of other cases and conflicting deadlines also

support the requested extension. These include:

• initiating appeals to the United States Court of Appeals for
the Fifth Circuit from a turnover order and the denial of a
motion to dissolve a writ of execution on a homestead,
preparing emergency motions to stay these orders pending
appeal, and initiating an appeal from the final judgment in
No. 4:22-CV-03731 in the United States District Court for
the Southern District of Texas, Houston Division; Fifth
Third Bank, National Association v. Saad Alsaab, et al.
(case settled on December 22, 2025);

• preparing a mandamus petition in the Supreme Court of
Texas for No. 03-25-00057-CV in the Third Court of
Appeals; In re Stallion Texas Real Estate Fund, LLC,
Austerra Texas Real Estate Fund, LLC, and Austerra Stable
Income Fund, LP;

• responding to a mandamus petition in No. 03-25-00974-CV
in the Third Court of Appeals; In re St. David’s Healthcare
Partnership, L.P., LLP d/b/a St. David’s North Austin
Medical Center (case settled on December 18, 2025);

• preparing a reply in support of a petition for review in No.
25-0662 in the Supreme Court of Texas; Todd Heath v.
Sunset Cliff Estates Road and Gate Maintenance, Inc.;

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• preparing appellant’s reply brief in No. 03-25-00223-CV in
the Third Court of Appeals; Kyle Grey Tillman, III v.
Theresa Cox;

• preparing appellant’s brief in No. 08-25-00270-CV in the
Eighth Court of Appeals; Stallion Texas Real Estate Fund,
LLC; Stallion Texas Real Estate Fund II – REIT, LLC; and
Austerra Stable Income Fund, LP v. NEU Module Estates,
LLC, Individually, and Derivatively on Behalf of NEU
Development Fund, LLC; and NEU Community Creekside,
LLC;

• preparing appellant’s brief in No. 03-25-00566-CV in the
Third Court of Appeals; William D. Shea v. Susan
Chambers, as Executor of The Estate of Marilyn Crawford;

• preparing appellant’s reply brief in No. 03-25-00043-CV in
the Third Court of Appeals; William Murphy a/k/a Billy
Murphy v. Daniel Cloyd Fusselman, Personally and as the
Representative of the Estate of T. W. Fusselman, Deceased;

• preparing appellant’s brief in No. 01-25-00278-CV in the
First Court of Appeals; Noble Capital Servicing, LLC
v. House Mosaic Holdings, LLC;

• handling pretrial issues, preparing for and attending a
December 22, 2025 pretrial hearing, and preparing for a
January 12, 2026 jury trial in Cause No. 25-BC08B-0001 in
the Business Court of Texas, Eighth Division; CRS
Mechanical Inc., CRS Mechanical of Nebraska, Inc.; and
Chris Allensworth v. Norfolk Cold Storage, LLC f/k/a TVG
Capital Holdings, LLC; and Jon Tryggestad; and

• handling pretrial issues and preparing for a January 26,
2026 jury trial in Cause No. D-1-GN-24-003215 in the 455th
Judicial District Court of Travis County, Texas; Levi
Bernard and Nadia Bernard, Individually and as Next
Friends of R.B. and S.B., Minor Children v. St. David’s
Healthcare Partnership, L.P., LLP d/b/a St. David's North
Austin Medical Center (case settled on December 18, 2025).

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4. Finally, the undersigned counsel’s workload has been

extremely heavy over the past few months, and he would like to take

some time away to be with his family over the holiday season.

CONCLUSION AND PRAYER

Appellant asks the Court to grant this motion and extend the

deadline for filing appellant’s brief to January 28, 2026.

Respectfully submitted,

By: /s/ D. Todd Smith
D. Todd Smith
State Bar No. 00797451
todd@texappcounsel.com

TEXAS APPELLATE COUNSEL PLLC
P.O. Box 160157
Austin, Texas 78716
737.313.8556

Counsel for Appellant
Medhat S.F. Michael, M.D.

CERTIFICATE OF CONFERENCE

On December 23, 2025, I attempted to confer with counsel for

Appellee, Ted Ross, about this motion. I received an email autoreply from

Mr. Ross informing me he will be out of the office and unavailable until

January 5, 2026. Therefore, although Appellee did not oppose the

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previous extensions, I cannot confirm whether Appellee’s position is the

same on this motion.

/s/ D. Todd Smith
D. Todd Smith

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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.

Robbie Burnett on behalf of D. Todd Smith
Bar No. 797451
robbie@texappcounsel.com
Envelope ID: 109415602
Filing Code Description: Motion
Filing Description: Third Motion for Extension of Time to File Appellant's
Brief
Status as of 12/23/2025 1:21 PM CST

Associated Case Party: Texas Medical Board

Name BarNumber Email TimestampSubmitted Status

Ted Ross ted.ross@oag.texas.gov 12/23/2025 1:18:47 PM SENT

Jeff Lutz jeff.lutz@oag.texas.gov 12/23/2025 1:18:47 PM SENT

Associated Case Party: Medhat S.F.Michael

Name BarNumber Email TimestampSubmitted Status

Jeff Henry jeff.henry@sprouselaw.com 12/23/2025 1:18:47 PM SENT

Angela Michael angelajonesmichael@yahoo.com 12/23/2025 1:18:47 PM SENT

D. Todd Smith todd@texappcounsel.com 12/23/2025 1:18:47 PM SENT

Robbie Burnett robbie@texappcounsel.com 12/23/2025 1:18:47 PM SENT