Jose A. Perez v. Texas Medical Board and Mari Robinson, JD, in Her Official Capacity

ACCEPTED
03-14-00644-CV
3844569
THIRD COURT OF APPEALS
AUSTIN, TEXAS
1/21/2015 1:08:57 PM
JEFFREY D. KYLE
CLERK
NO. 03-14-00644-CV
_____________________________________________________________
FILED IN
3rd COURT OF APPEALS
IN THE COURT OF APPEALS AUSTIN, TEXAS
THIRD DISTRICT OF TEXAS 1/21/2015 1:08:57 PM
AUSTIN, TEXAS JEFFREY D. KYLE
Clerk
_____________________________________________________________

JOSE A. PEREZ,
Appellant,
v.

TEXAS MEDICAL BOARD, et al.,
Appellees.
_____________________________________________________________

APPELLEES’ UNOPPOSED MOTION
FOR EXTENSION OF BRIEFING DEADLINE
_____________________________________________________________

TO THE HONORABLE JUSTICES OF THE THIRD COURT OF APPEALS:

Appellees, the Texas Medical Board, and Mari Robinson, JD, in her Official

Capacity; respectfully move this Court for an extension of the deadline for filing

their brief in the captioned appeal. In support, Appellees would show the Court as

follows:

1. Appellees’ brief is currently due on January 21, 2015. No previous

extensions have been requested or granted.

2. Appellees request an extension of time to file their brief to

February 18, 2015.
 3. The undersigned counsel for Appellees has hearings and matters

scheduled during the second half of January and the first half of February, 2015.

4. This Motion is not interposed for the purpose of delay, but only for

the purpose of allowing counsel to adequately prepare and file Appellees’ brief and

fully address the issues in this appeal.

Appellees therefore respectfully request an extension of time to, and

including, February 18, 2015, in which to file and serve their brief in the captioned

appeal.

Dated: January 21, 2015.

Respectfully submitted,

KEN PAXTON
Attorney General of Texas

CHARLES E. ROY
First Assistant Attorney General

JAMES E. DAVIS
Deputy Attorney General for Civil Litigation

DAVID A. TALBOT, JR.
Chief, Administrative Law Division

2
 /s/ Ted A. Ross
Ted A. Ross
Assistant Attorney General
State Bar No. 24008890
OFFICE OF THE TEXAS ATTORNEY GENERAL
ADMINISTRATIVE LAW DIVISION
P. O. Box 12548
Austin, Texas 78711-2548
Telephone: (512) 475-4191
Facsimile: (512) 457-4674
Email: ted.ross@texasattorneygeneral.gov
Attorneys for Appellees the Texas Medical Board
and Mari Robinson, JD, in her Official Capacity

CERTIFICATE OF CONFERENCE

I hereby certify that I contacted Appellant pro se and that he stated that he
does not oppose this motion.

/s/ Ted A. Ross
Ted A. Ross
Assistant Attorney General

CERTIFICATE OF SERVICE

I hereby certify that, in compliance with Rule 9.5 of the Texas Rules of
Appellate Procedure, a true and correct copy of the above and foregoing document
has been served on the following on this the 21st day of January 2015:

Jose A. Perez, pro se Via: Electronic Mail and
34 Candle Pine Place CMRRR #7006 2150 0005 6812 6472
The Woodlands, Texas 77381
Email: theaesculapius@gmail.com

/s/ Ted A. Ross
Ted A. Ross
Assistant Attorney Genera
3