Whittney Ford v. the University of Texas at Austin
Opinion
ACCEPTED 15-25-00123-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 8/26/2025 12:54 PM No. 15-25-00123-CV CHRISTOPHER A. PRINE ______________________________ CLERK FILED IN 15th COURT OF APPEALS IN THE COURT OF APPEALS AUSTIN, TEXAS FOR THE FIFTEENTH JUDICIAL DISTRICT 8/26/2025 12:54:39 PM ______________________________CHRISTOPHER A. PRINE Clerk
WHITTNEY FORD, Plaintiff/Appellant,
v.
JIM DAVIS AND THE UNIVERSITY OFTEXAS AT AUSTIN, Defendants/Appellees
On Appeal from Cause No. D-1-GN-24-002171, in the 261st District Court of Travis County, Texas
APPELLEES JIM DAVIS AND THE UNIVERSITY OF TEXAS AT AUSTIN’S UNOPPOSED MOTION TO EXTEND TIME TO FILE APPELLEES’ BRIEF
TO THE HONORABLE FIFTEENTH COURT OF APPEALS:
Appellees, Jim Davis, in his official capacity as President of The University of
Texas at Austin, and the University of Texas at Austin, pursuant to Tex. R. App. P.
38.6(d), file this Unopposed Motion to Extend Time to File Appellees’ Brief and
would respectfully shows as follows:
1. The deadline for Appellees’ Brief is set for September 15, 2025.
2. Appellees’ counsel requests a 30-day extension to this deadline, until
October 15 2025, to file Appellees’ Brief.
3. Among other matters, Appellees’ counsel Rachel Behrendt is
representing the Texas Comptroller in an upcoming weeklong jury trial in
September, in Arnulfo P. Alcorta, et al. v. Glenn Allen Hegar, Jr., Texas Comptroller of
Public Accounts, Cause No. D-1-GN-17-006831 in the 200th Judicial District, Travis
County, TX; and presently has a deadline for a Motion for Summary Judgment and
response to a Motion for Summary Judgment due in October in Alan Scott Caver v.
Attorney General of Texas, Cause No. CIV23-0603 in the 411th District Court of Polk
County, TX, which she will need to submit earlier due to an upcoming medical
procedure that she will be taking a substantial amount of leave for. Likewise,
Appellee’s counsel Zachary Rhines has a full caseload, with likewise has a full
caseload, with his work on League of United Latin American Citizens, et al., v. Greg
Abbott, in his official capacity as Governor of the State of Texas, et al., Case No. 3:21-
CV-00259-DCG-JES-JVB in the United States District Court for the Western
District of Texas as well as an appellate brief due on September 22, 2025.
4. The undersigned respectfully requests additional time to review
Whittney Ford’s Appellant’s Brief and adequately brief the relevant issues.
5. This is Appellees’ first request for an extension in this case. This
request is sought not for the purposes of delay, but so that justice may be done.
6. On August 26, 2025, the undersigned conferred with Appellant, who is
unopposed to the requested extension.
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
KIMBERLY GDULA Division Chief, General Litigation Division
/s/ Rachel L. Behrendt RACHEL L. BEHRENDT Texas Bar No. 24130871 Assistant Attorney General
ZACHARY L. RHINES Texas Bar No. 24116957 Special Counsel
P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Telephone: (737) 231-8329 Facsimile: (512) 320-0667 Rachel.Behrendt@oag.texas.gov Zachary.Rhines@oag.texas.gov
ATTORNEYS FOR APPELLEES
CERTIFICATE OF CONFERENCE
On August 26, 2025, counsel for Appellees conferred with Appellant Whittney Ford, regarding the foregoing motion. Mr. Ford informed the undersigned that he is not opposed to this motion.
/s/ Rachel L. Behrendt RACHEL L. BEHRENDT Assistant Attorney General
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing instrument has been served on August 26, 2025, on the following parties by e-service:
Martin Cohick State Bar No. 24134042 Assistant Attorney General Administrative Law Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Telephone: (512) 936-1317 Facsimile: (512) 320-0167 martin.cohick@oag.texas.gov
Counsel for Texas Attorney General Ken Paxton
Whittney Ford 4151 Wellborn Road Apartment 1101A Bryan, Texas 77801 Tel: (979) 264-4944 wjacksonford@gmail.com
Plaintiff Pro Se
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.
Ariana Ines on behalf of Rachel Behrendt Bar No. 24130871 ariana.ines@oag.texas.gov Envelope ID: 104858422 Filing Code Description: Motion Filing Description: APPELLEES JIM DAVIS AND THE UNIVERSITY OF TEXAS AT AUSTINS UNOPPOSED MOTION TO EXTEND TIME TO FILE APPELLEES BRIEF Status as of 8/26/2025 1:36 PM CST
Associated Case Party: The University of Texas at Austin
Name BarNumber Email TimestampSubmitted Status
Zachary Rhines 24116957 zachary.rhines@oag.texas.gov 8/26/2025 12:54:39 PM SENT
Martin Cohick 24134042 martin.cohick@oag.texas.gov 8/26/2025 12:54:39 PM SENT
Rachel Behrendt 24130871 rachel.behrendt@oag.texas.gov 8/26/2025 12:54:39 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Wolfgang P.Hirczy de Mino wphdmphd@gmail.com 8/26/2025 12:54:39 PM SENT
Ariana Ines ariana.ines@oag.texas.gov 8/26/2025 12:54:39 PM SENT
Associated Case Party: Whittney Ford
Name BarNumber Email TimestampSubmitted Status
Whitney Ford wjacksonford@gmail.com 8/26/2025 12:54:39 PM SENT
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