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
6/25/2025 2:16 PM
No. 15-25-00064-CV CHRISTOPHER A. PRINE CLERK
IN THE FIFTEENTH COURT OF APPEALS FILED IN 15th COURT OF APPEALS
AUSTIN, TEXAS
6/25/2025 2:16:29 PM
CHRISTOPHER A. PRINE
TEXAS STATE BOARD OF SOCIAL WORKER EXAMINERS , ET AL., Clerk
Appellants,
v.
KATHERIN YOUNIACUTT AND TAMMY THOMPSON, Appellees.
Appeal from the 345th Judicial District Court of Travis County, Texas Trial Case No. D-1-GN-24-009236
APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME
TO THE HONORABLE FIFTEENTH COURT OF APPEALS:
Appellees move to extend the time to file their opening brief, pursuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6(d). Appellants do not oppose the requested extension.
I.
Appellees opening brief is currently due on July 8, 2025. Appellants seek a 30-day extension, creating a new deadline of August 7, 2025. This is Appellees’ first request for an extension.
II.
Appellees request this extension due to the complexity of the issues on appeal and to accommodate the schedule of Appellees’ counsel, James Knight. Mr. Knight’s recent and upcoming deadlines include drafting a response brief to a motion to compel due June 23, 2025, in Schmidt, et al. v. City of Norfolk, et al., No. 2:24-cv-621, in the Eastern District of Virginia, discovery objections and responses in the same case due June 24 and July 9, 2025, respectively, as well as ongoing discovery in other cases. Mr. Knight is also out of the office on a pre-planned vacation from July 3, 2025, through July 20, 2025. Mr. Knight’s co-counsel, Arif Panju, is drafting briefs due on July 18 and July 25, 2025, and preparing for an oral argument scheduled for August 5, 2025, in McEwen, et al. v. Bill Lee, Governor, et al., No. 20-0242-II consolidated with No. 20-0143-II, in the Chancery Court of Tennessee, Davidson County.
Appellees do not seek this extension for delay and no party will be prejudiced if it is granted.
III.
Appellees respectfully request that the Court grant a 30-day extension of the deadline for filing Appellees’ opening brief, extending the deadline to and including August 7, 2025.
Dated: June 25, 2025. Respectfully submitted,
Arif Panju /s/ James T. Knight II (TX Bar No. 24070380) James T. Knight II* Institute for Justice (D.C. Bar No. 1671382) 816 Congress Avenue, Suite 970 Andrew Ward* Austin, TX 78701 (NY Bar No. 5364393) Tel.: (512) 480-5936 Institute for Justice apanju@ij.org 901 N. Glebe Rd., Suite 900 Arlington, VA 22203
(703) 682-9320
jknight@ij.org
award@ij.org
Counsel for Appellees *Admitted pro hac vice
CERTIFICATE OF SERVICE
I hereby certify that on June 25, 2025, a true and correct copy of the foregoing motion was filed with the Clerk of Court and served in compliance with the Texas Rules of Appellate Procedure via the Court’s electronic filing system on the following counsel of record:
Beth Klusmann Office of the Attorney General P.O. Box 12548 (MC 059) Austin, Texas 78711-2548 Tel.: (512) 936-1914 Fax: (512) 474-2697 Beth.Klusmann@oag.texas.gov
Counsel for Appellants
/s/ James T. Knight II___________ James T. Knight II
CERTIFICATE OF CONFERENCE As required by Texas Rules of Appellate Procedure 10.1(a)(5), I certify to the Court that I conferred with opposing counsel on June 23, 2025, about the merits of this motion and opposing counsel has indicated that she does not oppose the motion.
/s/ James T. Knight II___________ James T. Knight II
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.
Arif Panju on behalf of Arif Panju Bar No. 24070380 apanju@ij.org Envelope ID: 102421989 Filing Code Description: Motion Filing Description: APPELLEES UNOPPOSED MOTION FOR EXTENSION OF TIME Status as of 6/25/2025 2:21 PM CST
Associated Case Party: Katherin Youniacutt and Tammy Thompson Name BarNumber Email TimestampSubmitted Status Arif Panju 24070380 apanju@ij.org 6/25/2025 2:16:29 PM SENT James T. Knight II jknight@ij.org 6/25/2025 2:16:29 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 6/25/2025 2:16:29 PM SENT Beth Klusmann beth.klusmann@oag.texas.gov 6/25/2025 2:16:29 PM SENT Ali Thorburn 24125064 ali.thorburn@oag.texas.gov 6/25/2025 2:16:29 PM SENT Eric Abels Eric.Abels@oag.texas.gov 6/25/2025 2:16:29 PM SENT
Case Contacts Name BarNumber Email TimestampSubmitted Status Nancy Villarreal nancy.villarreal@oag.texas.gov 6/25/2025 2:16:29 PM SENT Andrew Ward andrew.ward@ij.org 6/25/2025 2:16:29 PM SENT Ashlynn Acosta aacosta@ij.org 6/25/2025 2:16:29 PM SENT Claire Purple cpurple@ij.org 6/25/2025 2:16:29 PM SENT
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