Texas Department of Public Safety v. Leroy Torres
Opinion
ACCEPTED 15-24-00089-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 12/17/2024 4:31 PM No. 15-24-00089-CV CHRISTOPHER A. PRINE CLERK IN THE COURT OF APPEALS FILED IN FOR THE FIFTEENTH JUDICIAL DISTRICT AUSTIN, TEXAS 15th COURT OF APPEALS
AUSTIN, TEXAS 12/17/2024 4:31:55 PM
CHRISTOPHER A. PRINE Clerk TEXAS DEPARTMENT OF PUBLIC SAFETY, Defendant-Appellant, v.
LEROY TORRES, Plaintiff-Appellee.
On Appeal from the County Court at Law Number One Nueces County, Texas Trial Court Cause No. 2017-CCV-61016-1
APPELLANT TEXAS DEPARTMENT OF PUBLIC SAFETY’S MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S REPLY BRIEF
KEN PAXTON KIMBERLY GDULA Attorney General of Texas Chief, Law Enforcement Defense
BRENT WEBSTER JASON T. CONTRERAS* First Assistant Attorney General Assistant Attorney General Texas Bar No. 24032093 RALPH MOLINA Office of the Attorney General Deputy First Assistant General Litigation Division Attorney General Post Office Box 12548 Austin, Texas 78711-2548 JAMES LLOYD (512) 463-2120 / (512) 320-0667 Deputy Attorney General for jason.contreras@oag.texas.gov Defense Litigation
*Counsel of Record
TO THE HONORABLE FIFTEENTH COURT OF APPEALS:
Pursuant to the Texas Rules of Appellate Procedure 10.5(b) and 38.6(d),
Appellant, the Texas Department of Public Safety, respectfully moves to extend time
to file its reply brief to January 24, 2025. Counsel for Appellee has indicated that he
is not opposed to this request.
Appellant’s Brief is currently due on January 6, 2025. Appellant’s counsel
will be out of the country during the holidays and will not return until January 7,
2025. As a result, there is insufficient time to review Appellee’s Brief and draft,
revise, and finalize the Brief by the current deadline.
CONCLUSION
Accordingly, Appellant respectfully requests that the Court grant this motion
thereby extending the deadline to file its reply Brief to January 24, 2025.
Respectfully submitted. KEN PAXTON Attorney General of Texas
BRENT WEBSTER First Assistant Attorney General
RALPH MOLINA Deputy First Assistant Attorney General
JAMES LLOYD Deputy Attorney General for Civil Litigation
KIMBERLY GDULA Chief, General Litigation Division
/s/ Jason T. Contreras JASON T. CONTRERAS Assistant Attorney General Texas Bar No. 24032093 Office of the Attorney General General Litigation Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Phone: 210-270-1109 Fax: 512-320-0667 Email: Jason.Contreras@oag.texas.gov Attorneys for Defendant
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing document was served electronically through the electronic-filing manager, File and Serve Texas, on December 17, 2024 to:
Stephen J. Chapman Webb Cason & Manning, P.C. 710 N. Mesquite Street Corpus Christi, TX 78401 steve@wcctxlaw.com; service@wcctxlaw.com
Brian J. Lawler Pro Hac Vice Pilot Law, P.C. 4632 Mt. Gaywas Drive San Diego, CA 92117 blawler@pilotlawcorp.com Counsel for Plaintiff
/s/ Jason T. Contreras Jason T. Contreras 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.
Nicole Myette on behalf of Jason Contreras Bar No. 24032093 nicole.myette@oag.texas.gov Envelope ID: 95423974 Filing Code Description: Motion Filing Description: 20241217_Aplnts MET File Reply Brief Status as of 12/17/2024 4:54 PM CST
Associated Case Party: Leroy Torres
Name BarNumber Email TimestampSubmitted Status
Stephen Chapman 24001870 steve@wcctxlaw.com 12/17/2024 4:31:55 PM SENT
Brian J.Lawler blawler@pilotlawcorp.com 12/17/2024 4:31:55 PM SENT
Matthew Manning 24075847 service@wcctxlaw.com 12/17/2024 4:31:55 PM SENT
Associated Case Party: Texas Department of Public Safety
Name BarNumber Email TimestampSubmitted Status
Jason Contreras Jason.contreras@oag.texas.gov 12/17/2024 4:31:55 PM SENT
Nicole A.Myette nicole.myette@oag.texas.gov 12/17/2024 4:31:55 PM SENT
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