Shamrock Psychiatric Clinic, P.A. v. Texas Health and Human Services Commission Charles Smith, Executive Commissioner of the Texas Health and Human Services Commission And Stuart W. Bowen Jr., Inspector General for the Texas Health and Human Services Commission Office of Inspector General

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ACCEPTED 03-15-00349-CV 7871147 THIRD COURT OF APPEALS AUSTIN, TEXAS 11/17/2015 3:58:09 PM JEFFREY D. KYLE CLERK NO. 03-15-00349-CV In the FILED IN 3rd COURT OF APPEALS Third Court of Appeals AUSTIN, TEXAS Of Texas 11/17/2015 3:58:09 PM JEFFREY D. KYLE Clerk SHAMROCK PSYCHIATRIC, P.A. Appellants, V. TEXAS HEALTH AND HUMAN SERVICES COMMISSION, KYLE JANEK, MD, EXECUTIVE COMM’R AND DOUGLAS WILSON, INSPECTOR GENERAL Appellees, On appeal from the 126th District Court, Travis County, Texas Cause NO. D-1-GV-14-001833 FIRST UNOPPOSED MOTION TO EXTEND TIME TO FILE REPLY BRIEF Appellant asks the Court to extend the time to file Appellant’s Reply Brief for an extension of 20 days. A. Introduction 1. Appellant is Shamrock Psychiatric, P.A. 2. This motion is filed within the period to file a motion to extend the time to file briefs, as required by Rules 10.5 and 38.6. 3. The Appellees are not opposed to this motion. Appellant Shamrock Psychiatric, P.A.’s Motion to Extend Time to File Reply Brief Page 1 of 3 B. Argument & Authorities 4. The Court may grant an extension of time to file briefs under Texas Rule of Appellate Procedure 38.6. 5. The deadline to file the Reply Brief is November 19, 2015. 6. Appellant requests this extension due to counsel having: - Intervening cases that had immediate impending deadlines preventing a timely reply brief to be completed; - A week-long out-of-state administrative law conference that occurred in the past month; - Unexpected contract negotiations required in a separate matter that distracted the undersigned counsel from reviewing and addressing Appellee’s brief for over a week. 7. No previous extension has been requested or granted to extend the time to file Appellant’s Brief. C. Prayer 8. For these reasons, Appellant asks the Court to grant an extension of time to file Brief until December 9, 2015. Appellant Shamrock Psychiatric, P.A.’s Motion to Extend Time to File Reply Brief Page 2 of 3 Respectfully Submitted, ___________________________ Jason Ray State Bar No. 24000511 RIGGS & RAY, P.C. 506 West 14th Street Austin, Texas 78701 (512) 457-9806 Telephone (512) 457-9066 Facsimile jray@r-alaw.com ATTORNEY FOR APPELLANT CERTIFICATE OF CONFERENCE I communicated by email on November 17, 2015 with opposing counsel, Eugene A. Clayborn and he advised that he does not oppose this motion. ___________________________ Jason Ray CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served by eservice on November 17, 2015 to the following: Eugene A. Clayborn Assistant Attorney General Deputy Chief, Administrative Law Division Office of the Attorney General of Texas P.O. Box 125548, Capitol Station Austin, Texas 78711-2548 Eugene.clayborn@texasattorneygeneral.gov ___________________________ Jason Ray Appellant Shamrock Psychiatric, P.A.’s Motion to Extend Time to File Reply Brief Page 3 of 3