Jose A. Perez v. Texas Medical Board and Mari Robinson, JD, in Her Official Capacity

Opinion

ACCEPTED 03-14-00644-CV 4676007 THIRD COURT OF APPEALS AUSTIN, TEXAS 3/27/2015 2:43:25 PM JEFFREY D. KYLE CLERK NO. 03-14-00644-CV _____________________________________________________________ FILED IN 3rd COURT OF APPEALS IN THE COURT OF APPEALS AUSTIN, TEXAS THIRD DISTRICT OF TEXAS 3/27/2015 2:43:25 PM AUSTIN, TEXAS JEFFREY D. KYLE Clerk _____________________________________________________________

JOSE A. PEREZ, Appellant, v.

TEXAS MEDICAL BOARD, et al., Appellees. _____________________________________________________________

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF BRIEFING DEADLINE _____________________________________________________________

TO THE HONORABLE JUSTICES OF THE THIRD COURT OF APPEALS:

Appellees, the Texas Medical Board, and Mari Robinson, JD, in her Official

Capacity; respectfully move this Court for an extension of the deadline for filing

their brief in response to Appellant’s amended brief in the captioned appeal. In

support, Appellees would show the Court as follows:

1. Appellees’ response to Appellant’s amended brief is currently due on

March 30, 2015. No previous extensions have been requested or granted.

2. Appellees request an extension of time to April 7, 2015 in which to

file their responsive brief. 3. The undersigned counsel for Appellees had several conflicts during

the weeks of March 16 and 23, including emergency hearings and other matters.

In addition, the Office of the Attorney General is closed on Friday, April 3.

4. This Motion is not interposed for the purpose of delay, but only for

the purpose of allowing counsel to adequately prepare and file Appellees’

responsive brief and fully address the issues raised therein.

5. Appellant pro se has advised that he does not oppose the requested

extension.

Appellees therefore respectfully request an extension of time to, and

including, April 7, 2015, in which to file and serve their brief in the captioned

appeal.

Dated: March 27, 2015.

Respectfully submitted,

KEN PAXTON Attorney General of Texas

CHARLES E. ROY First Assistant Attorney General

JAMES E. DAVIS Deputy Attorney General for Civil Litigation

DAVID A. TALBOT, JR. Chief, Administrative Law Division

2 /s/ Ted A. Ross Ted A. Ross Assistant Attorney General State Bar No. 24008890 OFFICE OF THE TEXAS ATTORNEY GENERAL ADMINISTRATIVE LAW DIVISION P. O. Box 12548 Austin, Texas 78711-2548 Telephone: (512) 475-4191 Facsimile: (512) 457-4674 Email: ted.ross@texasattorneygeneral.gov Attorneys for Appellees the Texas Medical Board and Mari Robinson, JD, in her Official Capacity

CERTIFICATE OF CONFERENCE

I hereby certify that I contacted Appellant pro se and that he stated that he does not oppose this motion.

/s/ Ted A. Ross Ted A. Ross Assistant Attorney General

CERTIFICATE OF SERVICE

I hereby certify that, in compliance with Rule 9.5 of the Texas Rules of Appellate Procedure, a true and correct copy of the above and foregoing document has been served on the following on this the 27th day of March 2015:

Jose A. Perez, pro se Via: Electronic Mail and 34 Candle Pine Place CMRRR #7012 1010 0002 4081 4946 The Woodlands, Texas 77381 Email: theaesculapius@gmail.com

/s/ Ted A. Ross Ted A. Ross Assistant Attorney Genera 3