Jorge R. Guevara, M.D. v. Texas Medical Board

Opinion

ACCEPTED 15-25-00036-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 7/16/2025 9:45 AM CASE NO. 15-25-00036-CV CHRISTOPHER A. PRINE __________________________________________________________________ CLERK FILED IN 15th COURT OF APPEALS IN THE COURT OF APPEALS AUSTIN, TEXAS FOR THE FIFTEENTH DISTRICT OF TEXAS AT AUSTIN 7/16/2025 9:45:41 AM __________________________________________________________________ CHRISTOPHER A. PRINE Clerk

JORGE R. GUEVARA, M.D., Appellant,

v.

TEXAS MEDICAL BOARD Appellee. __________________________________________________________________

APPELLEE TEXAS MEDICAL BOARD’S FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF __________________________________________________________________

TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

In accordance with Texas Rules of Appellate Procedure 10.5(b) and

38.6(d), Appellee the Texas Medical Board (TMB) respectfully requests a

30-day extension of time to file its brief. In support of the motion,

Appellee TMB would show the following:

1. The deadline for filing Appellee’s brief is currently July 30,

2025.

Motion for Extension of Time Page 1 of 4 2. Appellee TMB requests a 30-day extension from the current

deadline to file its brief. If granted, this extension would cause Appellee’s

brief to be due on August 29, 2025.

3. Counsel for TMB requires an extension due to multiple

competing deadlines, including an August 6, 2025, deadline to submit a

petition for review to the Texas Supreme Court. Counsel for Appellant

does not oppose the requested extension.

4. No previous motions for extension of time to file Appellee’s

brief have been filed.

WHEREFORE, PREMISES CONSIDERED, Appellee TMB

respectfully requests that this honorable Court grant its motion for

extension of time.

Respectfully submitted,

KEN PAXTON Attorney General of Texas

BRENT WEBSTER First Assistant Attorney General

RALPH MOLINA Deputy First Assistant Attorney General

Motion for Extension of Time Page 2 of 4 AUSTIN KINGHORN Deputy Attorney General for Civil Litigation

ERNEST C. GARCIA Chief, Administrative Law Division

/s/Kathy Johnson KATHY JOHNSON Assistant Attorney General Texas State Bar No. 24126964 Ted A. Ross Assistant Attorney General State Bar No. 24008890 Office of the Attorney General Administrative Law Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Telephone: (512) 475-4164 Facsimile: (512) 320-0167 kathy.johnson@oag.texas.gov

ATTORNEYS FOR APPELLEE TEXAS MEDICAL BOARD

Motion for Extension of Time Page 3 of 4 CERTIFICATE OF CONFERENCE

I hereby certify that I have conferred with Hayley Ellison, counsel

for Appellant Dr. Guevara, by email on July 15, 2025. Appellant does not

oppose the granting of the relief requested in this motion.

/s/Kathy Johnson KATHY JOHNSON ASSISTANT ATTORNEY GENERAL

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoing motion was

served on the following counsel of record for Appellant by electronic

service and/or e-mail on July 16, 2025:

Hayley Ellison Davis & Santos, PLLC 719 S. Flores St. San Antonio, TX 78204 P: 210-853-5882 hellison@dslawpc.com

ATTORNEY FOR APPELLANT

/s/Kathy Johnson KATHY JOHNSON ASSISTANT ATTORNEY GENERAL

Motion for Extension of Time Page 4 of 4 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.

Jeff Lutz on behalf of Kathy Johnson Bar No. 24126964 jeff.lutz@oag.texas.gov Envelope ID: 103190422 Filing Code Description: Motion Filing Description: 2025 0716 Appellee Motion for Extension Status as of 7/16/2025 9:49 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Jason M.Davis jdavis@dslawpc.com 7/16/2025 9:45:41 AM SENT

Ted Ross 24008890 Ted.Ross@oag.texas.gov 7/16/2025 9:45:41 AM SENT

Jeff Lutz jeff.lutz@oag.texas.gov 7/16/2025 9:45:41 AM SENT

Hayley Ellison hellison@dslawpc.com 7/16/2025 9:45:41 AM SENT

Katherine Johnson 24126964 kathy.johnson@oag.texas.gov 7/16/2025 9:45:41 AM SENT