Dawn Buckingham, M.D., as the Land Commissioner of the Texas General Land Office v. Lone Oak Club, LLC

ACCEPTED
15-25-00133-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
1/9/2026 12:07 PM
No. 15-25-00133-CV CHRISTOPHER A. PRINE
CLERK
FILED IN
15th COURT OF APPEALS
In The Fifteenth Court of Appeals AUSTIN, TEXAS
1/9/2026 12:07:15 PM
CHRISTOPHER A. PRINE
Clerk
DAWN BUCKINGHAM, M.D., AS THE LAND COMMISSIONER OF THE
TEXAS GENERAL LAND OFFICE,

Appellant

v.

LONE OAK CLUB, LLC,

Appellee.

Appeal from Cause No. CV27446-A in the 253rd District Court of
Chambers County, Texas

APPELLEE’S UNOPPOSED MOTION FOR AN EXTENSION OF TIME
TO FILE APPELLEE’S BRIEF

TO THE HONORABLE COURT OF APPEALS:

Comes Now, Appellee, Lone Oak Club, LLC, and files Appellee’s Unopposed

Motion for an Extension of Time to File Appellee’s Brief and, by such motion,

would respectfully show as follows:

1. The current deadline for filing Appellee’s Brief is January 21, 2026.

2. The Court has authority under TEX. R. APP. P. 38(d) to extend the time

to file a brief.

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3. This extension is requested because Appellee’s attorney is unable to

complete the brief by the due date for the following reasons:

• Appellee’s undersigned counsel is a sole practitioner, and as a
result of the Christmas Holidays and other family holiday
commitments, he was unable to work on Appellee’s Brief during
the period of December 23, 2025, through January 5, 2026;

• Since January 5, 2026, Appellee’s counsel has been unable to
complete the brief due to prior work deadlines in Cause No.
202526274, San Saba Energy, LP, et al v. Ballard Exploration
Company, Inc., in the 164th District Court of Harris County,
Texas – namely, reviewing for relevance and privilege for his
client’s production thousands of pages of documents, including
thousands of emails and text messages, which tasks will consume
at least another week or more.

4. Appellee respectfully requests a thirty (30) day extension of time to file

Appellee’s Brief, which would make Appellee’s Brief due on or before February

20, 2026.

5. Appellant is unopposed to the Court granting Appellee’s motion to

extend the time for the filing of Appellee’s Brief.

6. This is Appellee’s first motion for an extension of time for the filing of

its brief. This request is not made for the purposes of delay, but so that justice may

be done.

WHEREFORE, PREMISES CONSIDERED, Appellee, Lone Oak Club, LLC

respectfully prays that this Court grant this motion and enter an Order extending the

time for filing Appellee’s Brief to February 20, 2026.

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Respectfully submitted,

THE NORWOOD LAW FIRM

By: /s/ E. R. Norwood
E. R. Norwood
State Bar No. 15113500
340 Main Street
Liberty, Texas 77575
Telephone: 936-336-3700
Facsimile: 936-336-7634
enorwood@ednorwoodlaw.com

ATTORNEY FOR APPELLEE,
LONE OAK CLUB, LLC

CERTIFICATE OF CONFERENCE

I hereby certify that I have conferred with Mr. Ken Slavin, counsel for
Appellant, by email on January 8, 2026. Counsel for the Appellant, Mr. Slavin,
stated that Appellant is not opposed to this motion.

/s/ E. R. Norwood
E. R. Norwood

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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing instrument has
been served on the following opposing counsel by Electronic Service on this 9th day
of January, 2026:

Ken Slavin
State Bar No. 18496100
KEMP SMITH LLP
221 North Kansas, Suite 1700
El Paso, Texas 79901
Ken.Slavin@kempsmith.com
Deborah C. Trejo
State Bar No. 24007004
KEMP SMITH LLP
2905 San Gabriel St., Suite 205
Austin, Texas 78705
Deborah.Trejo@kempsmith.com

Attorneys for Appellant, Dawn Buckingham, M.D., as Commissioner of the Texas
General Land Office

/s/ E. R. Norwood
E. R. Norwood

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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.

Envelope ID: 109865870
Filing Code Description: Motion
Filing Description: Appellee's Unopposed Motion for an Extension of Time
to File Appellee's Brief
Status as of 1/9/2026 12:37 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Deborah Trejo deborah.trejo@kempsmith.com 1/9/2026 12:07:15 PM SENT

Rachel Moreno rachel.moreno@kempsmith.com 1/9/2026 12:07:15 PM SENT

Greta Duran greta.duran@kempsmith.com 1/9/2026 12:07:15 PM SENT

Sharnezia Mitchell sharnezia.mitchell@kempsmith.com 1/9/2026 12:07:15 PM SENT

Terry Castillo terry.castillo@kempsmith.com 1/9/2026 12:07:15 PM SENT

Ken Slavin ken.slavin@kempsmith.com 1/9/2026 12:07:15 PM SENT

Ed Norwood enorwood@ednorwoodlaw.com 1/9/2026 12:07:15 PM SENT