Texas Health and Human Services Commission v. Jessica Canto

Opinion

ACCEPTED 15-24-00080-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 6/13/2025 12:03 PM CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS June 13, 2025 6/13/2025 12:03:32 PM CHRISTOPHER A. PRINE Mr. Christopher A. Prine Clerk Via E-File Clerk of the Court Fifteenth Court of Appeals P.O. Box 12852 Austin, Texas 78711

Re: No. 15-24-00080-CV; Texas Health and Human Services Commission v. Jessica Canto, In the Fifteenth District Court of Appeals, Austin, Texas

Dear Mr. Prine:

As requested, I am providing an update on the status of the agreed supplemental administrative record. HHSC filed the Notice of Filing the Supplemental Administrative Record on May 27, 2025. The record was hand-delivered to the District Clerk on May 28, 2025. Proof that the agreed supplemental administrative record was submitted to and received by the District Clerk for filing is attached to this letter.

In both the Notice of Filing and the letter accompanying the record, the District Clerk was informed that the Court required submission of the record no later than June 2, 2025. See Enclosures. Counsel for HHSC is unaware of the reason for the delay in submitting the record to the Court or how much additional time the District Clerk needs to submit the record.

Respectfully Submitted,

/s/ Rosalind Hunt Rosalind Hunt Assistant Attorney General Administrative Law Division Office of the Attorney General of Texas

P ost O f fic e Bo x 12 54 8 , Au sti n, Te xa s 7 87 1 1- 25 48 • ( 51 2) 46 3- 2 1 00 • ww w.te xas atto r ne ygener al .go v P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Telephone: (512) 475-4166 Rosalind.Hunt@oag.texas.gov ATTORNEY FOR APPELLANT TEXAS HEALTH AND HUMAN SERVICES COMMISSION

Encl: HHSC’s Notice of Filing the Supplemental Administrative Record & Proof of Receipt cc: Kim Cox Via Email: kimacox@aol.com 5/27/2025 12:44 PM Velva L. Price District Clerk Travis County D-1-GN-19-008542 Cause No. D-1-GN-19-008542 Nancy Rodriguez

JESSICA CANTO, § IN THE DISTRICT COURT OF Plaintiff, § § v. § § CHARLES SMITH, EXECUTIVE § TRAVIS COUNTY, TEXAS COMMISSIONER OF TEXAS § HEALTH AND HUMAN SERVICES § COMMISSION § Defendant. § 353rd JUDICIAL DISTRICT

TEXAS HEALTH AND HUMAN SERVICES COMMISSION’S NOTICE OF FILING OF SUPPLEMENTAL ADMINISTRATIVE RECORD ________________________________________________________________

Appellant Texas Health and Human Services Commission (HHSC)

hereby files this notice of filing the supplemental administrative record with

the Travis County District Clerk pursuant to Texas Government Code

§ 2001.175(b). The certified supplemental administrative record contains one

363-page pdf document on a USB flash drive. The supplemental administrative

record will be transmitted to the District Clerk on a USB flash drive. Prior to

the filing of this notice, a copy of the complete administrative record was

provided to all parties for review.

Please note that this matter is on appeal and the supplemental

administrative record needs to be transmitted to the Fifteenth Court of

Appeals no later than June 2, 2025, in accordance with the attached notice. Respectfully submitted,

KEN PAXTON Attorney General of Texas

BRENT WEBSTER First Assistant Attorney General

RALPH MOLINA Deputy First Assistant Attorney General

AUSTIN KINGHORN Deputy Attorney General for Civil Litigation

ERNEST C. GARCIA Chief, Administrative Law Division

/s/ Rosalind L. Hunt______________ ROSALIND L. HUNT State Bar No. 24067108 Assistant Attorney General Administrative Law Division Office of the Attorney General of Texas P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Telephone: (512) 475-4166 Rosalind.Hunt@oag.texas.gov

ATTORNEYS FOR DEFENDANT TEXAS HEALTH AND HUMAN SERVICES COMMISSION

Page 2 CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document has been served on May 27, 2025, on the following attorneys via e-service and/or electronic transmission:

Kim Cox State Bar No. 04951500 Attorney at Law 4101 S. Alameda Corpus Christi, Texas 78411 Telephone: (361) 883-3265 kimacox@aol.com

ATTORNEY FOR PLAINTIFF JESSICA CANTO

/s/ Rosalind L. Hunt_____________ ROSALIND L. HUNT ATTORNEY FOR DEFENDANT

Page 3 FILE COPY

Chief Justice Clerk SCOTT BRISTER CHRISTOPHER A. PRINE Justices SCOTT FIELD APRIL FARRIS

Fifteenth Court of Appeals P.O. Box 12852, AUSTIN, TEXAS 78711 www.txcourts.gov/15thcoa/ 512-463-1610

Thursday, May 22, 2025

Rosalind L. Hunt Kim Cox Office of the Attorney General Attorney at Law Administrative Law Division 4101 S. Alameda P. O. Box 12548, Capitol Station Corpus Christi, TX 78411 Austin, TX 78711-2548 * DELIVERED VIA E-MAIL * * DELIVERED VIA E-MAIL *

RE: Court of Appeals Number: 15-24-00080-CV Trial Court Case Number: D-1-GN-19-008542

Style: Texas Health and Human Services Commission v. Jessica Canto

Please be advised that the Agreed Motion to Correct the Administrative Record was GRANTED by this Court on the date noted above. The corrected Administrative Record is due in this Court on or before June 2, 2025.

Sincerely,

____________________________ Christopher A. Prine, Clerk

cc: Velva L. Price (DELIVERED VIA E-MAIL) 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.

Rosalind Hunt on behalf of Rosalind Hunt Bar No. 24067108 rosalind.hunt@oag.texas.gov Envelope ID: 101276147 Filing Code Description: Notice Filing Description: TEXAS HEALTH AND HUMAN SERVICES COMMISSION'S NOTICE OF FILING OF SUPPLEMENTAL ADMINISTRATIVE RECORD Status as of 5/28/2025 11:42 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Rosalind Hunt rosalind.hunt@oag.texas.gov 5/27/2025 12:44:21 PM SENT

Kim Cox 4951500 kimacox@aol.com 5/27/2025 12:44:21 PM ERROR

Associated Case Party: TEXAS HEALTH AND HUMAN SERVICES COMMISSION

Name BarNumber Email TimestampSubmitted Status

Jennifer Foster Jennifer.Foster@oag.texas.gov 5/27/2025 12:44:21 PM SENT 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.

Jennifer Foster on behalf of Rosalind Hunt Bar No. 24067108 jennifer.foster@oag.texas.gov Envelope ID: 101991336 Filing Code Description: Letter Filing Description: 2n Ltr Re Clerks Record Status as of 6/13/2025 12:07 PM CST

Associated Case Party: Tex Health & Human Services Comm

Name BarNumber Email TimestampSubmitted Status

Rosalind Hunt rosalind.hunt@oag.texas.gov 6/13/2025 12:03:32 PM SENT

Associated Case Party: Jessica Canto

Name BarNumber Email TimestampSubmitted Status

Pamela MWilliams pmrshwms40@aol.com 6/13/2025 12:03:32 PM SENT

Kim ACox kimacox@aol.com 6/13/2025 12:03:32 PM ERROR

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Jennifer Foster Jennifer.Foster@oag.texas.gov 6/13/2025 12:03:32 PM SENT

Kim Cox kimacox@aol.com 6/13/2025 12:03:32 PM ERROR