Texas Health and Human Services Commission v. Shanressa Craddock

Opinion

ACCEPTED 15-25-00010-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 2/7/2025 11:05 AM No. 15-25-00010-CV CHRISTOPHER A. PRINE CLERK

In the Court of Appeals FILED IN 15th COURT OF APPEALS for the Fifteenth Judicial District AUSTIN, TEXAS ______________________________ 2/7/2025 11:05:37 AM CHRISTOPHER A. PRINE Clerk T EXAS H EALTH AND H UMAN S ERVICES C OMM ISSION , Defendant-Appellant, v.

S HANRESSA C RADDOCK , Plaintiff-Appellee. ______________________________

On Appeal from the 250th Judicial District Court, Travis County, Texas Cause No. D-1-GN-22-007315 ______________________________

APPELLANT’S MOTION TO WITHDRAW AND NOTICE OF LEAD COUNSEL ______________________________

Appellant, Texas Health and Human Services Commission, would show the

Court the following:

1. The current counsel on behalf of Appellant is Mason R. Currah.

2. Mr. Currah has accepted a position outside of the division handling this

matter and requests to withdraw from this case. Appellant designates Jennifer Cook

as new lead counsel. Ms. Cook is licensed to practice law in the state of Texas and is

a member in good standing of the State Bar of Texas. Ms. Cook’s contact information

is as follows:

1 JENNIFER COOK Assistant Attorney General General Litigation Division Office of the Attorney General P.O. Box 12548/Mail Stop 019-1 Austin, Texas 78711-2548 Tel: (512) 475-4098 Fax: (512) 302-0667 jennifer.cook@oag.texas.gov

3. Appellant respectfully requests that the Court remove Mr. Currah as

counsel of record and attorney-in-charge for this cause.

4. The undersigned has conferred with counsel for Plaintiff-Appellee, who

indicated they are unopposed to the withdrawal of Mr. Currah and substitution of

Ms. Cook as counsel in charge of Appellant.

PRAYER

Appellant requests that Ms. Cook be added to all future correspondence and

notifications of filings in this matter and be substituted as lead counsel, and that Mr.

Currah be removed as counsel of record.

Respectfully submitted.

KEN PAXTON Attorney General

BRENT WEBSTER First Assistant Attorney General

JAMES LLOYD Deputy Attorney General for Civil Litigation

KIMBERLY GDULA Chief, General Litigation Division

2 /s/ Mason Currah MASON CURRAH Texas Bar No. 24133305 Assistant Attorney General General Litigation Division Office of the Attorney General P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Phone: (512) 475-4072 Fax: (512) 320-0667 Mason.Currah@oag.texas.gov Counsel for Appellant

CERTIFICATE OF CONFERENCE

On February 4th, 2025, the undersigned conferred with lead counsel for Appellee, who stated they are unopposed to the relief requested.

/s/ Mason Currah MASON CURRAH

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing instrument has been served electronically through the electronic-filing manager on February 7, 2025 to all counsel of record.

/s/ Mason Currah MASON CURRAH

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.

Tristan Garza on behalf of Mason Currah Bar No. 24133305 tristan.garza@oag.texas.gov Envelope ID: 97111010 Filing Code Description: Motion Filing Description: APPELLANTS MOTION TO WITHDRAW AND NOTICE OF LEAD COUNSEL Status as of 2/7/2025 12:01 PM CST

Associated Case Party: Texas Health an Human Services Commission

Name BarNumber Email TimestampSubmitted Status

Mason Currah mason.currah@oag.texas.gov 2/7/2025 11:05:37 AM SENT

Tristan AGarza tristan.garza@oag.texas.gov 2/7/2025 11:05:37 AM SENT

Associated Case Party: Shanressa Craddock

Name BarNumber Email TimestampSubmitted Status

David Beyleryan dbeyleryan@lonestarlegal.org 2/7/2025 11:05:37 AM SENT

Elizabeth Ewing eewing@lonestarlegal.org 2/7/2025 11:05:37 AM SENT