Texas Health and Human Services Commission; Cecile Erwin Young, Executive Commissioner; Laura Castillo, Director of Heightened Monitoring; And Department of Family and Protective Services v. Kenneth Collier, Taneshu Collier, TRELS Home for Children, and TRELS Home LLC

Opinion

ACCEPTED 15-25-00182-cv

FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS

11/20/2025 10:33 AM

No. 15-25-00182-CV CHRISTOPHER A. PRINE CLERK

FILED IN

In the Court of Appeals 15th COURT OF APPEALS AUSTIN, TEXAS

for the Fifteenth Judicial District 11/20/2025 10:33:43 AM Austin, Texas CHRISTOPHER A. PRINE Clerk

Texas Health and Human Services Commission, Et Al., Appellants,

V.

Kenneth Collier, Taneshu Collier, TRELS Home for Children, and TRELS Home LLC

Appellees.

On Appeal from the 345th Judicial District Court, Travis County, Texas Cause Number D-1-GN-25-004379

Appellants’ Opposed First Motion for Extension of Time to File Appellants’ Brief

KEN PAXTON KIMBERLY GDULA Attorney General of Texas Chief for General Litigation Division

BRENT WEBSTER KELSEY HANSON First Assistant Attorney General Assistant Attorney General Texas Bar No. 24096654

RALPH MOLINA Deputy First Assistant Attorney Office of the Attorney General General General Litigation Division P.O. Box 12548, Capitol Station AUSTIN KINGHORN Austin, Texas 78711-2548 Deputy Attorney General for Civil (737) 224-1244| FAX: (512) 320-0667 Litigation Kelsey.hanson@oag.texas.gov

MOTION TO EXTEND

1. Appellants ask the Court to grant an extension of fourteen (14) days to file

their brief, extending the due date from December 2, 2025, to December 16, 2025.

2. This is Appellants’ first request for an extension of time to file their brief.

3. Good cause exists for the Court to grant this extension.

4. The undersigned counsel, Kelsey Hanson, (1) must prepare for and attend a

hearing setting on another client’s Plea to the Jurisdiction and Motion to Stay

Discovery in Cause No. D-1-GN-24-003265 in Travis County District Court on

November 25, 2025; and (2) the undersigned counsel’s office is closed on

November 27, 2025, and November 28, 2025, for the Thanksgiving holiday.

5. Additionally, Appellants’ client representatives who will need to review and

approve of the Appellants’ brief prior to filing also have office closures for their

respective agencies the week of November 24, 2025, as well as personal

commitments related to the Thanksgiving holiday the week of November 24, 2025.

6. Due to these reasons and other time constraints, Appellants require

additional time to submit their Appellants’ Brief.

7. This extension is not being sought for purposes of delay but so that justice

may be done.

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8. The undersigned counsel conferred with counsel for Appellees, Ms. Kyle

Ferguson, via email on November 20, 2025, and Ms. Kyle Ferguson indicated that

Appellees are opposed to Appellants’ request for a 14-day extension of the due date

for Appellants’ Brief.

9. All facts recited in this motion are within the personal knowledge of the

undersigned counsel, so no verification is necessary under Texas Rule of Appellate

Procedure 10.2.

PRAYER

Appellants request that this motion be granted, extending the time for filing

Appellants’ Brief to December 16, 2025.

KEN PAXTON KIMBERLY GDULA Attorney General of Texas Chief for General Litigation Division

BRENT WEBSTER KELSEY HANSON First Assistant Attorney General Assistant Attorney General Texas Bar No. 24096654

RALPH MOLINA Deputy First Assistant Attorney Office of the Attorney General General General Litigation Division P.O. Box 12548, Capitol Station AUSTIN KINGHORN Austin, Texas 78711-2548 Deputy Attorney General for Civil (737) 224-1244| FAX: (512) 320-0667 Litigation Kelsey.hanson@oag.texas.gov

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CERTIFICATE OF CONFERENCE

Kelsey Hanson conferred with Ms. Kyle Ferguson, counsel for Appellees, by email on November 20, 2025. Appellees are opposed to this motion.

/s/ Kelsey Hanson KELSEY HANSON Assistant Attorney General

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoing was filed electronically and that notice of this filing will be sent to the following persons through File & Serve Texas’s electronic filing system on November 20, 2025:

Kyle Ferguson John Ferguson Meghan Rudnai Ferguson Law Practice, PLLC 1017 RR 620 S., Suite 222 Lakeway, TX 78734 Telephone: (512) 996-5407 Attorneys For Appellees

/s/ Kelsey Hanson Kelsey Hanson 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.

Kelsey Hanson on behalf of Kelsey Hanson Bar No. 24096654 kelsey.hanson@oag.texas.gov Envelope ID: 108274534 Filing Code Description: Motion Filing Description: 20251120 Appellants First MTE to file Brief Status as of 11/20/2025 10:43 AM CST

Associated Case Party: TEXAS HEALTH AND HUMAN SERVICES COMMISSION

Name BarNumber Email TimestampSubmitted Status

Chelsea Goodman chelsea.goodman@oag.texas.gov 11/20/2025 10:33:43 AM SENT

Kelsey Hanson kelsey.hanson@oag.texas.gov 11/20/2025 10:33:43 AM SENT

Associated Case Party: KENNETH COLLIER

Name BarNumber Email TimestampSubmitted Status

Kyle Ferguson kyle@fergusonlawpractice.com 11/20/2025 10:33:43 AM SENT

John Ferguson john@fergusonlawpractice.com 11/20/2025 10:33:43 AM SENT

Meghan Rudnai meghan@fergusonlawpractice.com 11/20/2025 10:33:43 AM SENT