Patricia Mosley// Texas Health and Human Services Commission and Texas Department of Family and Protective Services v. Texas Health and Human Services Commission and Texas Department of Family and Protective Services// Cross-Appellee, Patricia Mosley
This text of Patricia Mosley// Texas Health and Human Services Commission and Texas Department of Family and Protective Services v. Texas Health and Human Services Commission and Texas Department of Family and Protective Services// Cross-Appellee, Patricia Mosley (Patricia Mosley// Texas Health and Human Services Commission and Texas Department of Family and Protective Services v. Texas Health and Human Services Commission and Texas Department of Family and Protective Services// Cross-Appellee, Patricia Mosley) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
ACCEPTED 03-16-00358-CV 12595326 THIRD COURT OF APPEALS AUSTIN, TEXAS 9/8/2016 2:49:12 PM JEFFREY D. KYLE CLERK No. 03-16-00358-CV
IN THE COURT OF APPEALS FILED IN FOR THE THIRD DISTRICT OF TEXAS 3rd COURT OF APPEALS AUSTIN, TEXAS AUSTIN, TEXAS 9/8/2016 2:49:12 PM JEFFREY D. KYLE Clerk PATRICIA MOSLEY, Appellant/Cross-Appellee,
V.
TEXAS HEALTH AND HUMAN SERVICES COMMISSION AND TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES, Appellees/Cross-Appellants.
ON APPEAL FROM THE 201ST JUDICIAL DISTRICT COURT, TRAVIS COUNTY, TEXAS, CAUSE NO. D-1-GN-15-001024
CROSS-APPELLEE’S FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE CROSS-APPELLEE’S RESPONSE BRIEF
BAKER BOTTS L.L.P.
98 San Jacinto Blvd., Suite 1500 Kevin E. Vickers Austin, Texas 78701-4078 State Bar No. 24079517 512.322.2500 (phone) kevin.vickers@bakerbotts.com 512.322.2501 (fax) Paulina Williams State Bar No. 24066295 paulina.williams@bakerbotts.com
Samia R. Broadaway State Bar No. 24088322 samia.broadaway@bakerbotts.com
ATTORNEYS FOR PATRICIA MOSLEY September 8, 2016 TO THE HONORABLE JUSTICES OF THE THIRD COURT OF APPEALS:
Pursuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6,
Appellant/Cross-Appellee Patricia Mosley respectfully submits this unopposed
motion for an extension of time to file Cross-Appellee’s response brief, seeking an
extension of 30 days, through and until October 14, 2016.
Currently, Cross-Appellee Patricia Mosley’s response brief is due on or
before September 14, 2016. Appellant respectfully requests an extension of 30
days, through and until October 14, 2016, to file her response brief. This is Cross-
Appellee’s first request for an extension of time to file her response brief.
Appellees/Cross-Appellants Texas Health and Human Services Commission and
Texas Department of Family and Protective Services do not oppose the extension.
Cross-Appellee Patricia Mosley requests an extension not for purposes of
delay, but because Cross-Appellee’s counsel have a number of professional
obligations in pending matters that impair their ability to prepare a brief by the
current September 14, 2016, deadline.
Kevin Vickers’s professional commitments include: (1) providing counsel
on a complex regulatory compliance matter involving administrative enforcement
by the Texas Commission on Environmental Quality; (2) providing counsel
regarding pending National Environmental Policy Act environmental review;
(3) providing counsel regarding claims under the Federal Tort Claims Act; and
1 (4) preparing for proceedings in Texans Against High Speed Rail, Inc. v. Ken
Paxton and Texas Department of Transportation, Cause No. D-1-GN-16-000942,
126th Judicial District, Travis County, Texas.
Paulina Williams’ professional obligations include: (1) providing counsel on
multiple compliance and permitting related filings with the Texas Commission on
Environmental Quality; and (2) providing counsel in multiple time-sensitive
transactions.
Samia Rogers Broadaway’s professional obligations include: (1) preparing
for litigation related to Clean Air Act matters; and (2) providing counsel regarding
compliance with Clean Water Act requirements.
For these reasons, Cross-Appellee respectfully requests that the Court grant
her an extension of 30 days, through and until October 14, 2016, to file her
response brief. Cross-Appellee requests such further relief to which she may be
justly entitled.
2 Respectfully submitted,
/s/ Kevin E. Vickers Kevin E. Vickers State Bar No. 24079517 kevin.vickers@bakerbotts.com Paulina Williams State Bar No. 24066295 paulina.williams@bakerbotts.com Samia R. Broadaway State Bar No. 24088322 samia.broadaway@bakerbotts.com 98 San Jacinto Blvd., Suite 1500 Austin, Texas 78701-4078 512.322.2500 (phone) 512.322.2501 (fax)
ATTORNEYS FOR PATRICIA MOSLEY
3 CERTIFICATE OF CONFERENCE I certify that I conferenced with Andrew Lutostanski, counsel for Appellees/Cross-Appellants Texas Health and Human Services Commission and Texas Department of Family and Protective Services, on September 8, 2016, concerning this motion, and Mr. Lutostanski responded that Cross-Appellants Texas Health and Human Services Commission and Texas Department of Family and Protective Services do not oppose the motion.
/s/ Kevin E. Vickers Kevin E. Vickers
CERTIFICATE OF SERVICE I certify that a true and correct copy of this First Unopposed Motion for Extension of Time to File Cross-Appellee’s Response Brief was served on all counsel of record listed below on September 8, 2016, via electronic service:
Andrew Lutostanski Office of the Texas Attorney General P.O. Box 12548 Austin, TX 78711-2548 Phone: (512) 475-4200 Fax: (512) 320-0167 andrew.lutostanski@texasattorneygeneral.gov (Attorney for Texas Health and Human Services Commission and Texas Department of Family and Protective Services)
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