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

Opinion

ACCEPTED

15-25-00017-CV

FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 6/26/2025 8:43 AM

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

In the Fifteenth Court of Appeals FILED IN 15th COURT OF APPEALS

Austin, Texas AUSTIN, TEXAS 6/26/2025 8:43:02 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

Appellant’s Motion to Extend Time to File Appellant’s Reply Brief (Unopposed)

Appellant files this unopposed motion seeking a 30-day extension of time

to file her Appellant’s Reply Brief to July 30, 2025.

1. Appellant’s Reply Brief is due on June 30, 2025.

2. Appellant requests a 30-day extension per Texas Rule of Appellate

Procedure 38.6(d). Appellant seeks an extension because for the past two and

a half weeks, her counsel has been occupied with preparing an emergency

petition for writ of mandamus, motion for emergency relief (for stay), and

amended petition in the Thirteenth Court of Appeals (which could not be

extended) and also a motion for new trial (which could not be extended)

involving a case over $8 million. The mandamus proceeding that cannot be

extended is expected to occupy most of her counsel’s time the week of June

30. Also, Appellant’s counsel is out of the office this week and will be out of

the office for additional days in the month of July.

3. Appellant seeks an extension for the Reply Brief in this Appeal so

that her counsel can brief the issues and provide this Court with helpful

arguments and legal authority.

4. This is Appellant’s first request for an extension of time for her Reply

Brief. Appellee, Texas Health and Human Services Commission, does not

oppose, and is in agreement with, an extension.

Prayer

Appellant respectfully requests that the Court grant an extension of time

until and including July 30, 2025 to file her Appellant’s Reply Brief and grant

her any other relief to which she may be justly entitled.

Respectfully submitted,

KEAN | MILLER LLP

By: /s/ Tracia Y. Lee

Tracia Y. Lee State Bar No. 24013021 Tracia.Lee@keanmiller.com Laurel M. Smith State Bar No. 24113488

3

Laurel.Smith@keanmiller.com Pennzoil South Tower 711 Louisiana Street, Suite 1800 Houston, Texas 77002 (713) 844-3000 (713) 844-3030 (Fax) e-serve@keanmiller.com (E-Service)

Attorneys for Appellant, Candice Jeffcoat

Certificate of Conference

I conferred with counsel for Appellee about this Motion, and she stated that Appellee does not oppose, and is in agreement with, an extension.

/s/ Tracia Y. Lee Tracia Y. Lee

Certificate of Service

I certify that a true and correct copy of the foregoing instrument was sent via e-serve on this 26th day of June 2025 to the following:

Terri M. Abernathy Jonathan Petix Assistant Attorney General Texas Health and Human Services General Litigation Division Commission (HHSC) Office of the Attorney General 350 Pine Street, 9th Floor 300 West 15th Street, 6th Floor Beaumont, Texas 77701 Austin Texas 78701 (409) 730-4087 Direct: (512) 979-5354 (409) 730-4048 (Fax) Fax: (512) 302-0667 Jonathan.petix@hhs.texas.gov Email: Terri.Abernathy@oag.texas.gov Counsel for Appellee, Texas Health and Human Services Commission (HHSC)

/s/ Tracia Y. Lee Tracia Y. Lee

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.

Tracia Lee on behalf of Tracia Lee Bar No. 24013021 tracia.lee@keanmiller.com Envelope ID: 102454250 Filing Code Description: Motion Filing Description: Appellant's Motion for Extension of Time to File Reply Brief (Unopposed) Status as of 6/26/2025 9:15 AM CST

Associated Case Party: Texas Health and Human Services Commission

Name BarNumber Email TimestampSubmitted Status

Jonathan Petix 24027728 jonathan.petix@hhs.texas.gov 6/26/2025 8:43:02 AM SENT

Terri Abernathy terri.abernathy@oag.texas.gov 6/26/2025 8:43:02 AM SENT

Quennette Rose Quennette.Rose@oag.texas.gov 6/26/2025 8:43:02 AM SENT

Tristan AGarza tristan.garza@oag.texas.gov 6/26/2025 8:43:02 AM SENT

Reed Arroyo reed.arroyo@oag.texas.gov 6/26/2025 8:43:02 AM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Victoria Gomez victoria.gomez@oag.texas.gov 6/26/2025 8:43:02 AM SENT