Jamie Smith, in His Official Capacity as District Clerk of Jefferson County, Texas v. Megan Lavoie, in Her Official Capacity as Administrative Director Texas Office of Court Administration
Opinion
ACCEPTED
15-25-00015-CV
FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 3/27/2025 3:44 PM
No. 15-25-00015-CV CHRISTOPHER A. PRINE CLERK
FILED IN
15th COURT OF APPEALS
IN THE COURT OF APPEALS AUSTIN, TEXAS 3/27/2025 3:44:51 PM
FOR THE FIFTEENTH JUDICIAL DISTRICT OF TEXAS CHRISTOPHER A. PRINE
Clerk
JAMIE SMITH, IN HIS OFFICIAL CAPACITY AS DISTRICT CLERK OF JEFFERSON COUNTY, TEXAS, APPELLANT
V.
MEGAN LAVOIE, IN HER OFFICIAL CAPACITY AS ADMINISTRATIVE DIRECTOR TEXAS OFFICE OF COURT ADMINISTRATION, APPELLEE
On Appeal from the 455th Judicial District Court of Travis County, Texas, Cause No. D-1-GN-24-005976
APPELLANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF
Quentin D. Price Assistant District Attorney State Bar No. 16303740 Quentin.Price@jeffersoncountytx.gov 1085 Pearl St., 3rd Floor Beaumont, Texas 77701 (409) 835-8550- Telephone
ATTORNEY FOR APPELLANT JAMIE SMITH, in his official capacity as District Clerk of Jefferson County, Texas
TO THE HONORABLE COURT:
COMES NOW, APPELLANT, JAMIE SMITH, in his official capacity as
District Clerk of Jefferson County, Texas, in the above-entitled and numbered
cause, and makes this Unopposed Motion to Extend Time to File Appellant’s
Brief and would respectfully show the following:
INTRODUCTION
1. Appellant is JAMIE SMITH, in his official capacity as District Clerk of Jefferson County, Texas; Appellee is MEGAN LAVOIE, in her official capacity as Administrative Director Texas Office of Court Administration.
2. There is no specific deadline to file this motion to extend time. See Tex.R.App.P.38.6(d).
3. The other parties are unopposed to this motion.
ARGUMENT & AUTHORITIES
4. The Court has the authority under Texas Rule of Appellate Procedure 38.6(d) to extend the time to file a brief.
5. Appellant’s brief is currently due on March 31, 2025.
6. Jamie Smith, in his official capacity as District Clerk of Jefferson County, Texas requests an additional 30 days to file his brief, extending the time until April 30, 2025.
7. No extension has been granted to extend the time to file Appellant’s brief.
8. Counsel for Appellant had been preparing for an upcoming trial and attending the trial in an unrelated matter in the 136th Judicial District Court that began on March 17, 2025. Additionally, Counsel for Appellant has a regularly scheduled weekly hearing, other scheduled hearings in various cases that he has to prepare for, and handles all bail bond forfeiture cases for Jefferson County. Finally, Counsel for Appellant regularly answers legal questions from other offices in
Jefferson County that distracts from drafting the brief in question. Accordingly, Counsel for Appellant needs additional time to file his brief.
CONCLUSION
9. Appellant, JAMIE SMITH, in his official capacity as District Clerk of Jefferson County, Texas, is requesting his first extension due to Appellant’s counsel preparing for and attending trial and scheduled hearings in the State Court.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that the Court
grant this Unopposed Motion for Extension of Time to File Appellant’s Brief until
April 30, 2025.
Respectfully submitted
JEFFERSON COUNTY DISTRICT ATTORNEYS OFFICE
By: /s/ Quentin D. Price Quentin D. Price Assistant District Attorney 1085 Pearl St. Beaumont, Texas 77701 (409) 835-8550 Texas Bar# 16303740 Quentin.Price@jeffersontexas.tx.gov
Certificate of Conference
I hereby certify that I have contacted counsel for Appellant, Dustin Galmor, and he is unopposed to this request for an extension of time.
/s/ Quentin D. Price Quentin D. Price
Certificate of Service
I hereby certify that a true and correct copy of APPELLANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF has been forwarded to all counsel of records by E-FILE system on this 27th day of March, 2025.
/s/ Quentin D. Price QUENTIN D. PRICE
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.
Sandra Mott on behalf of Quentin Price Bar No. 16303740 sandra.mott@jeffersoncountytx.gov Envelope ID: 98982872 Filing Code Description: Motion Filing Description: Appellant's Unopposed Motion for Extension of Time to File Brief Status as of 3/27/2025 4:06 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Quentin D.Price Quentin.Price@jeffersoncountytx.gov 3/27/2025 3:44:51 PM SENT
Sandra Mott Sandra.Mott@jeffersoncountytx.gov 3/27/2025 3:44:51 PM SENT
William Farrell biff.farrell@oag.texas.gov 3/27/2025 3:44:51 PM SENT
Matthew Dow mdow@jw.com 3/27/2025 3:44:51 PM SENT
Nicole Myette nicole.myette@oag.texas.gov 3/27/2025 3:44:51 PM SENT
John Edwards jedwards@jw.com 3/27/2025 3:44:51 PM SENT
Free access — add to your briefcase to read the full text and ask questions with AI
Jamie Smith, in His Official Capacity as District Clerk of Jefferson County, Texas v. Megan Lavoie, in Her Official Capacity as Administrative Director Texas Office of Court Administration (Jamie Smith, in His Official Capacity as District Clerk of Jefferson County, Texas v. Megan Lavoie, in Her Official Capacity as Administrative Director Texas Office of Court Administration) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.