Home/Court of Appeals of Texas/Richard M. Young, Jr. A/K/A Richard Young v. Texas Parks and Wildlife Department, John Silovsky as Wildlife Division Director of Texas Parks and Wildlife Department, and the State of Texas

Richard M. Young, Jr. A/K/A Richard Young v. Texas Parks and Wildlife Department, John Silovsky as Wildlife Division Director of Texas Parks and Wildlife Department, and the State of Texas

Court of Appeals of Texas·Decided February 12, 2025·No. 15-24-00052-CV·Published

Opinion

ACCEPTED 15-24-00052-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 2/12/2025 7:20 PM No. 15-24-00052-CV CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS IN THE FIFTEENTH DISTRICT COURT OF APPEALS (AUSTIN ) TEXAS AUSTIN, 2/12/2025 7:20:19 PM CHRISTOPHER A. PRINE Clerk Richard M. YOUNG, Jr. a/k/a Richard Young, Appellant vs.

TEXAS PARKS & WILDLIFE DEPARTMENT, et al., Appellees.

APPELLANT’S UNOPPOSED SECOND MOTION FOR EXTENSION TO FILE REPLY BRIEF

Appellant Richard M. Young a/k/a Richard Young (“Young”) has a

Reply Brief due to this Court on February 18, 2025. Due to unforeseen

health issues (head injury),1 the undersigned needs more time to prepare

a Reply Brief responsive to the Brief filed by Appellees. Thus, Young

respectfully requests this Court grant him a 20-day extension to file his

1 The undersigned has had to spend extra time on testing (MRI w/o contrast, MRI w/contrast, CT w/o contrast, & CT w/contrast) over the past three weeks due to a head injury. The undersigned, based on this injury, has lost multiple work days to medical appointments to address this injury and to attend the multitude of testing ordered by medical professionals. Due to the significant issues presented by this case, some of which are issues of first impression for Texas law, the undersigned has been denied the time needed to properly brief a responsive filing in this extraordinary case. 1 Reply Brief, which would make Young’s Reply Brief due on March 10,

2025. Appellees are unopposed to this Motion.

Respectfully submitted,

Kimberly S. Keller KELLER STOLARCZYK PLLC 215 W. Bandera Road No. 114-PMB 800 Boerne, Texas 78006 Tele: 830.981.5000 /s/Kimberly S. Keller Kimberly S. Keller SBN: 24014182 Email: kim@kellsto.com

APPELLANT’S COUNSEL

CERTIFICATE OF CONFERENCE & SERVICE

On February 12, 2025, I conferred with Ian Lancaster, opposing

counsel, who advised Appellees are opposed to this Motion; further, on

this same date, this Motion was served on those listed below through this

Court’s e-filing service:

Counsel for Appellees:

KEN PAXTON, Attorney General of Texas; BRENT WEBSTER, First Asst. Attorney General; JAMES LLOYD, Deputy Attorney General for Civil Litigation; KELLIE E. BILLINGS-RAY, Chief, Environmental Protection Division, OFFICE OF THE ATTORNEY GENERAL, Environmental Protection Division, P.O. Box 12548, MC066, Austin, Texas 78711-2548

2 IAN LANCASTER, Asst. Attorney General, Email: ian.lancaster@oag.texas.gov

H. CARL MYERS, Asst. Attorney General, Email: carl.myers@oag.texas.gov

HEATHER COFFEE, Asst. Attorney General, Email: heather.coffee@oag.texas.gov

Counsel for Texas Animal Health Commission:

KAREN L. WATKINS, Asst. Attorney General, Administrative Law Division, Office of the Attorney General, P.O. Box 12548, Austin, Texas 78711, Email: karen.watkins@oag.texas.gov

/s/Kimberly S. Keller Kimberly S. Keller

3 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.

Kimberly Keller on behalf of Kimberly Keller Bar No. 24014182 kim@kellsto.com Envelope ID: 97320358 Filing Code Description: Motion Filing Description: Appellant's UNOPPOSED Second Extension (Based on Health Reasons) to File Reply Brief Status as of 2/13/2025 7:17 AM CST

Associated Case Party: State Of Texas

Name BarNumber Email TimestampSubmitted Status

Kellie E.Billings-Ray Kellie.Billings-Ray@oag.texas.gov 2/12/2025 7:20:19 PM SENT

Ian Lancaster ian.lancaster@oag.texas.gov 2/12/2025 7:20:19 PM SENT

Laura Courtney laura.courtney@oag.texas.gov 2/12/2025 7:20:19 PM SENT

H. CarlMyers Carl.Myers@oag.texas.gov 2/12/2025 7:20:19 PM SENT

James ScottMcCarley scott.mccarley@oag.texas.gov 2/12/2025 7:20:19 PM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Karen LWatkins karen.watkins@oag.texas.gov 2/12/2025 7:20:19 PM SENT

Kimberly SKeller kim@kellsto.com 2/12/2025 7:20:19 PM SENT

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Richard M. Young, Jr. A/K/A Richard Young v. Texas Parks and Wildlife Department, John Silovsky as Wildlife Division Director of Texas Parks and Wildlife Department, and the State of Texas, (Tex. Ct. App. 2025).

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