Texas State Board of Social Worker Examiners v. Katherin Youniacutt and Tammy Thompson

Opinion

ACCEPTED 15-25-00064-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 5/12/2025 3:24 PM No. 15-25-00064-CV CHRISTOPHER A. PRINE CLERK

In the Court of Appeals 15th COURT FILED IN OF APPEALS

for the Fifteenth Judicial District5/12/2025 3:24:28 PM AUSTIN, TEXAS

CHRISTOPHER A. PRINE Clerk Texas State Board of Social Worker Examiners, et al., Appellants, v.

Katherin Youniacutt and Tammy Thompson, Appellees.

On Appeal from the 345th Judicial District Court, Travis County

UNOPPOSED MOTION TO EXTEND TIME TO FILE APPELLANTS’ BRIEF

Pursuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), Appellants

move to extend the time to file their opening appellants’ brief by 30 days, from the

current deadline of May 19, 2025, to a proposed new deadline of June 18.

I.

The clerk’s record and reporter’s record in this case were filed on April 29,

2025, making appellants’ brief due on May 19. Tex. R. App. P. 38.6(a). Appellants

now request a 30-day extension of the time to file that brief, which would create a

new deadline of June 18. This is Appellants’ first request for an extension.

II.

This extension is not sought for delay but to accommodate the schedule of

Appellants’ counsel, Beth Klusmann. Ms. Klusmann’s recent and upcoming

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deadlines include drafting or assisting with the follow briefs: (1) reply brief on the

merits in State of Texas v. JRJ Pusok Holdings, LLC, No. 24-0447, due in the Texas

Supreme Court on May 19; (2) amicus brief in South Plains Sno, Inc. v. Eskimo Hut

Worldwide, Ltd., No. 24-0353, requested by the Texas Supreme Court and currently

due May 23; and (3) appellee’s brief in Rojas v. State of Texas, No. 01-25-00268-CV,

currently pending in the First Court of Appeals and due June 2. Ms. Klusmann is

also assisting a colleague prepare for oral argument before this Court in Texas A&M University v. Snider, No. 15-24-00071-CV, on May 20. And the Attorney General’s

Office will be closed for Memorial Day. Moreover, because Ms. Klusmann is new to

the case, additional time to review the record and to research and analyze the issues

presented in this appeal will allow for a thorough and helpful brief.

Accordingly, Appellants request an additional 30 days in which to prepare their

appellants’ brief. Appellees do not oppose this motion.

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Prayer For the foregoing reasons, Appellants respectfully request that the Court grant

them a 30-day extension to file their appellants’ brief, creating a new deadline of June

18.

Respectfully submitted.

Ken Paxton Aaron L. Nielson Attorney General of Texas Solicitor General

Brent Webster /s/ Beth Klusmann First Assistant Attorney General Beth Klusmann Assistant Solicitor General Office of the Attorney General State Bar No. 24036918 P.O. Box 12548 (MC 059) Beth.Klusmann@oag.texas.gov Austin, Texas 78711-2548 Tel.: (512) 936-1700 Fax: (512) 474-2697 Counsel for Appellants

Certificate of Conference I certify that on May 9, 2025, I conferred by email with James Knight, lead counsel for Appellees, and he does not oppose this motion.

/s/ Beth Klusmann Beth Klusmann

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.

Toni Shah on behalf of Beth Klusmann Bar No. 24036918 toni.shah@oag.texas.gov Envelope ID: 100727235 Filing Code Description: Motion Filing Description: 20250512 Youniacutt MET Status as of 5/12/2025 3:31 PM CST

Associated Case Party: Katherin Youniacutt and Tammy Thompson

Name BarNumber Email TimestampSubmitted Status

Arif Panju 24070380 apanju@ij.org 5/12/2025 3:24:28 PM SENT

James T. Knight II jknight@ij.org 5/12/2025 3:24:28 PM SENT

Associated Case Party: Texas State Board of Social Workers Examiners, et al.

Name BarNumber Email TimestampSubmitted Status

John Ramsey 24051227 John.Ramsey@oag.texas.gov 5/12/2025 3:24:28 PM SENT

Beth Klusmann beth.klusmann@oag.texas.gov 5/12/2025 3:24:28 PM SENT

Ali Thorburn 24125064 ali.thorburn@oag.texas.gov 5/12/2025 3:24:28 PM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Nancy Villarreal nancy.villarreal@oag.texas.gov 5/12/2025 3:24:28 PM SENT

Andrew Ward andrew.ward@ij.org 5/12/2025 3:24:28 PM SENT

Ashlynn Acosta aacosta@ij.org 5/12/2025 3:24:28 PM SENT

Claire Purple cpurple@ij.org 5/12/2025 3:24:28 PM SENT