Texas Health and Human Services Commission v. Shanressa Craddock

Court of Appeals of Texas·Decided February 25, 2025·No. 15-25-00010-CV·Published

Opinion

ACCEPTED 15-25-00010-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 2/25/2025 3:16 PM No. 15-25-00010-CV CHRISTOPHER A. PRINE _____________________________ CLERK FILED IN In the Court of Appeals 15th AUSTIN, COURT OF APPEALS TEXAS for the Fifteenth Judicial District2/25/2025 3:16:35 PM Austin, Texas CHRISTOPHER A. PRINE Clerk

TEXAS HEALTH AND HUMAN SERVICES COMMISSION Appellant,

v.

SHANRESSA CRADDOCK Appellee.

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

STATUS REPORT ON REQUEST FOR TRIAL COURT RECORD

15-25-00010-CV; Texas Health and Human Services Commission. v. Shanressa Craddock Status Report on Request for Trial Court Record Page 1 of 3

To the Honorable Fifteenth Court of Appeals:

Pursuant to a February 10, 2025 letter from the Clerk for the Fifteenth Court

of Appeals requesting Appellant, Texas Health and Human Services Commission,

to provide this Court with documentation that the trial court record has been

requested, Appellant files this status report to show Appellant has requested both the

reporter’s record and recorder’s record from the trial court.

In letters filed with the trial court and emailed to the trial court reporter and

the Travis County District Court Clerk on February 20, 2025, Appellant requested

both the reporter and recorder’s records for this case. In those letters, Appellant

asked to make payment arrangements. Appellant continues to work with both the

reporter and recorder to make payment for the records. Copies of the two letters—

one to the reporter and one to the recorder (which is the Clerk)—are attached as

Exhibit A.

Respectfully submitted,

KEN PAXTON Attorney General of Texas

BRENT WEBSTER First Assistant Attorney General

RALPH MOLINA Deputy First Assistant Attorney General

AUSTIN KINGHORN

15-25-00010-CV; Texas Health and Human Services Commission. v. Shanressa Craddock Status Report on Request for Trial Court Record Page 2 of 3

Deputy Attorney General for Civil Litigation

KIMBERLEY GDULA Chief - General Litigation Division

/s/Jennifer Cook JENNIFER COOK Assistant Attorney General Texas State Bar No. 00789233 General Litigation Division Office of the Attorney General P.O. Box 12548 Austin, Texas 78711-2548 Tel: (512) 475-4098 Fax: (512) 302-0667 jennifer.cook@oag.texas.gov

Attorney for Appellant, The Texas Health and Human Services Commission

15-25-00010-CV; Texas Health and Human Services Commission. v. Shanressa Craddock Status Report on Request for Trial Court Record Page 3 of 3 2/20/2025 3:05 PM Velva L. Price District Clerk Travis County D-1-GN-22-007315 Rosa Oneal

JENNIFER COOK PHONE: (512) 475-4098 Assistant Attorney General FAX: (512) 320-0667 General Litigation Division EMAIL: Jennifer.cook@oag.texas.gov February 20, 2025

Via electronic filing and email Jill Albracht, Court Reporter Travis County District Courthouse 1700 Guadalupe, 10th Floor Austin, TX 78701 jill.albracht@traviscountytx.gov

Re: REQUEST FOR REPORTER’S RECORD Cause No. D-1-GN-22-007315, Texas Health and Human Services Commission v. Shanressa Craddock, pending in the 250th District Court in Travis County, Texas

Dear Ms. Albracht:

Defendant, Texas Health and Human Services Commission, has filed its notice of appeal in this case.

Please prepare, file, and certify an original and one copy of the reporter’s record containing the record and arguments presented at any and all hearings for this case, including the hearing on November 14, 2024, and all exhibits. We would like the record available electronically.

In accordance with Texas Rule of Appellate Procedure 35.3(a), please notify Defendant of the cost of preparing the record so that arrangements can be made for prompt payment thereof.

Thank you for your assistance. If you have any questions or require anything else, please contact my legal assistant, Victoria Gomez at (512) 463-2100 or by email at victoria.gomez@oag.texas.gov.

Sincerely,

/s/ Jennifer Cook Jennifer Cook Assistant Attorney General

cc: Plaintiff’s counsel—via efile

P os t O f fic e Bo x 1 2 54 8 , Aust i n, Tex a s 7 8 7 1 1 - 2 5 4 8 • ( 5 1 2 ) 4 6 3 - 2 1 0 0 • ww w. t exa sat to r n eyg eneral .g ov

A

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.

Victoria Gomez on behalf of Jennifer Cook Bar No. 789233 victoria.gomez@oag.texas.gov Envelope ID: 97612905 Filing Code Description: Request Filing Description: REQUEST FOR REPORTER’S RECORD Status as of 2/21/2025 1:04 PM CST

Associated Case Party: SHANRESSA CRADDOCK

Name BarNumber Email TimestampSubmitted Status

David Beyleryan 24087164 dbeyleryan@lonestarlegal.org 2/20/2025 3:05:37 PM SENT

Elizabeth Ewing 24092396 eewing@lonestarlegal.org 2/20/2025 3:05:37 PM SENT

Associated Case Party: TEXAS HEALTH AND HUMAN SERVICES COMMISSION

Name BarNumber Email TimestampSubmitted Status

Jennifer Cook Jennifer.Cook@oag.texas.gov 2/20/2025 3:05:37 PM SENT

Victoria Gomez victoria.gomez@oag.texas.gov 2/20/2025 3:05:37 PM SENT 2/20/2025 12:48 PM Velva L. Price District Clerk Travis County D-1-GN-22-007315 Rosa Oneal

JENNIFER COOK PHONE: (512) 475-4098 Assistant Attorney General FAX: (512) 320-0667 General Litigation Division EMAIL: Jennifer.Cook@oag.texas.gov February 20, 2025

Via email and e-filing Travis County Courthouse District Clerk Travis County District Courthouse 1700 Guadalupe, 3rd Floor Austin, TX 78701 districtclerkhelp@traviscountytx.gov

Re: REQUEST FOR CLERK’S RECORD Texas Health and Human Services Commission v. Shanressa Craddock, No. D-1-GN- 22-007315, in the Travis County District Court, 250th Judicial District Appellate Docket Number: 15-25-00010-CV

Dear Clerk:

Defendant, Texas Health and Human Services Commission, has filed its notice of appeal in this case.

Defendant is appealing this case to the Fifteenth Court of Appeals. The trial court signed an order on December 31, 2024, finding that substantial evidence does not support Defendant’s administrative order and granting Plaintiff’s request for relief. Defendant filed a notice of appeal on January 30, 2025, and will request the reporter’s record.

Defendant requests that all pleadings, orders, notices, and other materials in the Court’s record for this cause be included in the Clerk’s Record, as required by Texas Rule of Appellate Procedure 34.5(a).

In accordance with Texas Rule of Appellate Procedure 35.3(a), please notify Defendant of the cost of preparing the record so that arrangements can be made for prompt payment thereof.

If you have any questions or require anything else, please contact my legal assistant, Victoria Gomez at (512) 475-4104 or by email at victoria.gomez@oag.texas.gov.

Very truly yours, /s/ Jennifer Cook Jennifer Cook Assistant Attorney General cc: Plaintiff’s counsel—via efile

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.

Victoria Gomez on behalf of Jennifer Cook Bar No. 789233 victoria.gomez@oag.texas.gov Envelope ID: 97601145 Filing Code Description: Request Filing Description: REQUEST FOR CLERK’S RECORD LETTER Status as of 2/21/2025 1:04 PM CST

Associated Case Party: SHANRESSA CRADDOCK

Name BarNumber Email TimestampSubmitted Status

David Beyleryan 24087164 dbeyleryan@lonestarlegal.org 2/20/2025 12:48:09 PM SENT

Elizabeth Ewing 24092396 eewing@lonestarlegal.org 2/20/2025 12:48:09 PM SENT

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Texas Health and Human Services Commission v. Shanressa Craddock, (Tex. Ct. App. 2025).

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