In the Guardianship of Landen Thomas Griswold, an Incapacitated Person v. the State of Texas

Court of Appeals of Texas·Decided April 24, 2025·No. 15-25-00017-CV·Published

Opinion

ACCEPTED

15-25-00017-CV

FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 4/24/2025 10:49 AM

No. 15-25-00017-CV CHRISTOPHER A. PRINE CLERK

FILED IN

In the Fifteenth Court of Appeals 15th COURT OF APPEALS AUSTIN, TEXAS

Austin, Texas

4/24/2025 10:49:00 AM CHRISTOPHER A. PRINE

Clerk

In the Guardianship of Landen Thomas Griswold, an Incapacitated Person

On Appeal from Cause No. G00074 County Court at Law Cherokee County, Texas

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

Pursuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6(d),

Appellee, Texas Health and Humas Services Commission (“Appellee”) files

this unopposed motion seeking a 20-day extension of time to file Appellee’s

Brief to May 27, 2025.1 In support of this motion, Appellee shows the

following:

1. Appellee’s Brief is due May 5, 2025.

2. The following grounds provide good cause for extending the time

to file Appellee’s Brief. Appellee’s former lead counsel, Alyssa Bixby-Lawson,

has accepted another position outside of the Texas Office of the Attorney

1 A 20-day extension from the current deadline of May 5, 2025, falls on Sunday, May 25.

2025; and, the following Monday, May 26, 2025, is Memorial Day.

General and outside of the State of Texas—her last day with the Texas Office

of the Attorney General is April 25, 2025. Appellee’s new and current lead

counsel, Reed S. Arroyo, was only recently assigned to represent Appellee in

this action on Friday, April 18, 2025. Due to Mr. Arroyo’s other

responsibilities in separate litigation matters, he was only able to meet and

confer with Mrs. Bixby-Lawson for the first time regarding this case on April

23, 2025. Consequently, Mr. Arroyo requires more time to review the filings

and to prepare Appellee’s brief.

3. This is the second request for an extension of time to file

Appellee’s Brief before this Court.

4. The motion is unopposed.
5. This motion is not filed for the purpose of delay, nor will

Appellant be harmed because Appellant is unopposed to this extension

request.

Prayer

For these reasons, Appellee respectfully request that the Court grant

an extension of time of 20-days to file Appellee’s Brief to May 27, 2025, and

grant it any other relief to which it may be justly entitled.

Respectfully submitted,

KEN PAXTON Attorney General

BRENT WEBSTER First Assistant Attorney General

RALPH MOLINA Deputy First Assistant Attorney General

AUSTIN KINGHORN Deputy Attorney General for Civil Litigation

KIMBERLY GDULA Chief, General Litigation Division /s/ Alyssa Bixby-Lawson ALYSSA BIXBY-LAWSON Texas Bar No. 24122680 Assistant Attorneys General General Litigation Division P.O. Box 12548 Austin, Texas 78711 (210) 270-1118 – Phone (512) 320-0667 – Fax alyssa.bixby-lawson@oag.texas.gov REED S. ARROYO Attorney in Charge Texas Bar No. 24143565 Assistant Attorney General General Litigation Division Office of the Attorney General P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Phone: (210) 270-1118 Fax: (512) 320-0667 Reed.Arroyo@oag.texas.gov

Counsel for Appellee

CERTIFICATE OF CONFERENCE

On April 23, 2025, the undersigned conferred with lead counsel for Appellee, who stated they are unopposed to the relief requested.

/s/ Alyssa Bixby-Lawson ALYSSA BIXBY-LAWSON

CERTIFICATE OF SERVICE

I certify that on April 24, 2025, a true and correct copy of this document was served via the court’s e-service system on the following counsel of record:

Tracia Y. Lee Tracia.Lee@keanmiller.com Laurel M. Smith Laurel.Smith@keanmiller.com Pennzoil South Tower 711 Louisiana Street, Suite 1800 Houston, Texas 77002 (713) 844-3000 e-serve@keanmiller.com

Counsel for Appellee

/s/ Alyssa Bixby-Lawson

ALYSSA BIXBY-LAWSON Assistant Attorney General

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.

Alyssa Bixby-Lawson on behalf of Alyssa Bixby-Lawson Bar No. 24122680 alyssa.bixby-lawson@oag.texas.gov Envelope ID: 100036416 Filing Code Description: Motion Filing Description: Unopposed Motion for Extension of Time to File Appellee's Brief Status as of 4/24/2025 11:55 AM CST

Associated Case Party: Texas Health and Human Services Commission

Name BarNumber Email TimestampSubmitted Status

Jonathan Petix 24027728 jonathan.petix@hhs.texas.gov 4/24/2025 10:49:00 AM SENT

Alyssa Bixby-Lawson 24122680 alyssa.bixby-lawson@oag.texas.gov 4/24/2025 10:49:00 AM SENT

Victoria Gomez victoria.gomez@oag.texas.gov 4/24/2025 10:49:00 AM SENT

Associated Case Party: Candice Jeffcoat

Name BarNumber Email TimestampSubmitted Status

Tracia Lee e-serve@keanmiller.com 4/24/2025 10:49:00 AM SENT

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In the Guardianship of Landen Thomas Griswold, an Incapacitated Person v. the State of Texas, (Tex. Ct. App. 2025).

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