John Eric Anderson v. State of Texas

Opinion

ACCEPTED

15-25-00132-CV

FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 1/8/2026 5:56 PM

No. 15-25-00132-CV CHRISTOPHER A. PRINE CLERK

IN THE COURT OF APPEALS FILED IN 15th COURT OF APPEALS

FOR THE FIFTEENTH JUDICIAL DISTRICT OF TEXASAUSTIN, TEXAS 1/8/2026 5:56:27 PM

AUSTIN, TEXAS CHRISTOPHER A. PRINE Clerk

J OH N E RIC ANDERSON , PLAINTIFF-APPELLANT,

V.

S TATE OF T EXAS, ET AL ., DEFENDANTS-APPELLEES

ON APPEAL FROM THE 98TH JUDICIAL DISTRICT COURT OF TRAVIS COUNTY, TEXAS; CAUSE NO. D-1-GN-001988

APPELLEES’ MOTION FOR FOURTEEN-DAY EXTENSION TO FILE APPELLEES’

BRIEF

KEN PAXTON BRIANA M. WEBB Attorney General of Texas Chief, Law Enforcement Defense Division

BRENT WEBSTER First Assistant Attorney General KYLE A. PERKINS* Assistant Attorney General AUSTIN KINGHORN Deputy Attorney General for Civil Litigation OFFICE OF THE ATTORNEY GENERAL P.O. Box 12548, Capitol Station Austin, Texas 78711

*ATTORNEY OF RECORD (512) 463-2080 (512) 936-2109

ATTORNEYS FOR DEFENDANTS-APPELLEES

Appellees the State of Texas, the Texas Department of Criminal Justice

(“TDCJ”), and TDCJ Executive Director Bryan Collier, submit this Motion for

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Extension of Time to File their Brief. In support of this motion, Appellees offer the

following:

Appellees’ brief is presently due on January 8, 2025. Appellees request the Court

grant them a fourteen (14) day extension of time―until January 22―in which to file

the responsive brief in this matter. AAG Perkins is preparing three motions for

summary judgment due within six days of each other. In order to effectively represent

Appellees’ best interest, this brief extension is respectfully requested.

This is Appellees’ second request for an extension. Good cause exists for the

granting of this Motion, which is not being presented for purposes of delay, nor for

purposes of prejudicing Appellant in prosecuting his appeal. Appellant is presumed to

be in opposition.

Respectfully submitted,

KEN PAXTON Attorney General of Texas

BRENT WEBSTER First Assistant Attorney General

RALPH MOLINA Deputy First Assistant Attorney General

AUSTIN KINGHORN Deputy Attorney General for Civil Litigation

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BRIANA M. WEBB Division Chief Law Enforcement Defense Division

/s/ Kyle A. Perkins KYLE A. PERKINS Assistant Attorney General Texas State Bar No. 24144087 Kyle.perkins@oag.texas.gov

Law Enforcement Defense Division OFFICE OF THE ATTORNEY GENERAL P.O. Box 12548 Austin, Texas 78711-2548 Phone (512) 463-2080 | Fax (512) 370-9814

ATTORNEYS FOR APPELLEES

CERTIFICATE OF CONFERENCE

I, KYLE A. PERKINS, Assistant Attorney General of Texas, do hereby certify

that due to Appellant’s incarcerated status, I am unable to confer with him. It is

presumed that Appellant is opposed.

/s/ Kyle A. Perkins KYLE A. PERKINS Assistant Attorney General

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CERTIFICATE OF SERVICE

I, KYLE A. PERKINS, Assistant Attorney General of Texas, do hereby certify

that a true and correct copy of the above and foregoing Motion for Extension has

been served via the Court’s electronic case filing service within one business day of

January 8, 2025, on the following:

John Eric Anderson, TDCJ # 00552116 CM/RRR: TDCJ – LeBlanc Unit 3695 FM 3514 Beaumont, TX 77705

PLAINTIFF PRO SE

/s/ Kyle A. Perkins KYLE A. PERKINS 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.

Gloriana Ojeda on behalf of Kyle Perkins Bar No. 24144087 gloriana.ojeda@oag.texas.gov Envelope ID: 109842154 Filing Code Description: Motion Filing Description: Anderson Appellee Brief MET 003 Status as of 1/9/2026 7:12 AM CST

Associated Case Party: State of Texas, et al.

Name BarNumber Email TimestampSubmitted Status

Kyle Perkins 24144087 Kyle.Perkins@oag.texas.gov 1/8/2026 5:56:27 PM SENT

Daniel Rosales daniel.rosales@oag.texas.gov 1/8/2026 5:56:27 PM SENT