Home/Court of Appeals of Texas/Chris Traylor, as Executive Commissioner of the Texas Health and Human Services Commission And the Texas Health and Human Services Commission v. Diana D., as Next Friend of KD, a Child Karen G., as Next Friend of TG and ZM, Children Guadalupe P., as Next Friend of LP, a Child Sally L., as Next Friend of CH, a Child Dena D., as Next Friend of BD, a Child OCI Acquisition, LLC

Chris Traylor, as Executive Commissioner of the Texas Health and Human Services Commission And the Texas Health and Human Services Commission v. Diana D., as Next Friend of KD, a Child Karen G., as Next Friend of TG and ZM, Children Guadalupe P., as Next Friend of LP, a Child Sally L., as Next Friend of CH, a Child Dena D., as Next Friend of BD, a Child OCI Acquisition, LLC

Court of Appeals of Texas·Decided November 20, 2015·No. 03-15-00657-CV·Published

Opinion

ACCEPTED 03-15-00657-CV 7927127 THIRD COURT OF APPEALS AUSTIN, TEXAS 11/20/2015 1:27:51 PM JEFFREY D. KYLE CLERK NO. 03-15-00657-CV

FILED IN 3rd COURT OF APPEALS IN THE AUSTIN, TEXAS THIRD COURT OF APPEALS 11/20/2015 1:27:51 PM AUSTIN, TEXAS JEFFREY D. KYLE Clerk

CHRIS TRAYLOR, EXECUTIVE COMMISSIONER OF TEXAS HEALTH AND HUMAN SERVICES COMMISSION AND THE TEXAS HEALTH AND HUMAN SERVICES COMMISSION, APPELLANTS

V.

DIANA D., et al APPELLEES

ON APPEAL FROM THE 200TH JUDICIAL DISTRICT COURT, TRAVIS COUNTY, TEXAS, HON. TIM SULAK, PRESIDING

UNOPPOSED MOTION REQUESTING EXTENSION OF TIME TO FILE APPELLEES’ BRIEF

TO THE HONORABLE THIRD COURT OF APPEALS:

Come now Appellees Diana D. et al. and submit this Motion For Extension

of Time to File Appellees’ Brief as follows.

1) Appellees’ Brief regarding the interlocutory appeal of the trial court’s grant

of a temporary injunction is due on December 2, 2015. Appellees are requesting a

thirty day extension of time to file Appellees’ Brief, which would make the brief

due on January 1, 2016. Appellees have not previously requested an extension of

time to file their brief.

2) Good cause exists for allowing Appellees additional time to file their Brief.

The parties have agreed to mediate this case in December. Appellees seek an

extension of time to permit the parties to mediate the case without incurring

additional litigation expenses involved with preparation of a brief in this matter in

the event that mediation is successful. The parties will inform the court of the

results of mediation.

3) This motion is not sought for delay but so that justice may be served.

Wherefore, Appellees pray that the Court grant their thirty day extension

request to file their Brief to January 1, 2016, and for such other relief to which they

may be entitled.

Respectfully submitted,

RICHARDS RODRIGUEZ & SKEITH, LLP 816 Congress Avenue, Suite 1200 Austin, Texas 78701 Telephone: 512-476-0005 Facsimile: 512-476-1513

By: /s/ Daniel R. Richards_____________ DANIEL R. RICHARDS State Bar No. 00791520 drichards@rrsfirm.com BENJAMIN H. HATHAWAY State Bar No. 09224500 bhathaway@rrsfirm.com CLARK RICHARDS State Bar No. 90001613 crichards@rrsfirm.com CHASE C. HAMILTON State Bar No. 24059881 chamilton@rrsfirm.com

ATTORNEYS FOR APPELLEES

CERTIFICATE OF CONFERENCE

Pursuant to Tex. App. R. 10.1(a)(5), I hereby certify that I have conferred with counsel for Appellants and Appellants do not oppose a thirty day extension of the deadline.

/s/ Daniel R. Richards_____________ DANIEL R. RICHARDS

CERTIFICATE OF SERVICE

I hereby certify that the foregoing document has been delivered to the following counsel of records on this, the 20th day of November 2015 by electronic notification and e-mail:

Kristofer S. Monson Assistant Solicitor General Office of the Attorney General of Texas P.O. Box 12548, (MC 059) Austin, Texas 78711-2548 Kristofer.monson@texasattorneygeneral.gov

/s/ Daniel R. Richards_____________ DANIEL R. RICHARDS

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Chris Traylor, as Executive Commissioner of the Texas Health and Human Services Commission And the Texas Health and Human Services Commission v. Diana D., as Next Friend of KD, a Child Karen G., as Next Friend of TG and ZM, Children Guadalupe P., as Next Friend of LP, a Child Sally L., as Next Friend of CH, a Child Dena D., as Next Friend of BD, a Child OCI Acquisition, LLC, (Tex. Ct. App. 2015).

Chris Traylor, as Executive Commissioner of the Texas Health and Human Services Commission And the Texas Health and Human Services Commission v. Diana D., as Next Friend of KD, a Child Karen G., as Next Friend of TG and ZM, Children Guadalupe P., as Next Friend of LP, a Child Sally L., as Next Friend of CH, a Child Dena D., as Next Friend of BD, a Child OCI Acquisition, LLC (Chris Traylor, as Executive Commissioner of the Texas Health and Human Services Commission And the Texas Health and Human Services Commission v. Diana D., as Next Friend of KD, a Child Karen G., as Next Friend of TG and ZM, Children Guadalupe P., as Next Friend of LP, a Child Sally L., as Next Friend of CH, a Child Dena D., as Next Friend of BD, a Child OCI Acquisition, LLC) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.