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

ACCEPTED
03-14-00644-CV
4676007
THIRD COURT OF APPEALS
AUSTIN, TEXAS
3/27/2015 2:43:25 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 3/27/2015 2:43:25 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 response to Appellant’s amended brief in the captioned appeal. In

support, Appellees would show the Court as follows:

1. Appellees’ response to Appellant’s amended brief is currently due on

March 30, 2015. No previous extensions have been requested or granted.

2. Appellees request an extension of time to April 7, 2015 in which to

file their responsive brief.
 3. The undersigned counsel for Appellees had several conflicts during

the weeks of March 16 and 23, including emergency hearings and other matters.

In addition, the Office of the Attorney General is closed on Friday, April 3.

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’

responsive brief and fully address the issues raised therein.

5. Appellant pro se has advised that he does not oppose the requested

extension.

Appellees therefore respectfully request an extension of time to, and

including, April 7, 2015, in which to file and serve their brief in the captioned

appeal.

Dated: March 27, 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

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 /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 27th day of March 2015:

Jose A. Perez, pro se Via: Electronic Mail and
34 Candle Pine Place CMRRR #7012 1010 0002 4081 4946
The Woodlands, Texas 77381
Email: theaesculapius@gmail.com

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