Chris Traylor, as Executive Commissioner of the Texas Health and Human Services Commission And the Texas Health and Human Services Commission v. Diana D., as Next Friend of KD, a Child Karen G., as Next Friend of TG and ZM, Children Guadalupe P., as Next Friend of LP, a Child Sally L., as Next Friend of CH, a Child Dena D., as Next Friend of BD, a Child OCI Acquisition, LLC

ACCEPTED
03-15-00657-CV
7927127
THIRD COURT OF APPEALS
AUSTIN, TEXAS
11/20/2015 1:27:51 PM
JEFFREY D. KYLE
CLERK
NO. 03-15-00657-CV

FILED IN
3rd COURT OF APPEALS
IN THE AUSTIN, TEXAS
THIRD COURT OF APPEALS 11/20/2015 1:27:51 PM
AUSTIN, TEXAS JEFFREY D. KYLE
Clerk

CHRIS TRAYLOR, EXECUTIVE COMMISSIONER OF TEXAS HEALTH
AND HUMAN SERVICES COMMISSION AND THE TEXAS HEALTH
AND HUMAN SERVICES COMMISSION,
APPELLANTS

V.

DIANA D., et al
APPELLEES

ON APPEAL FROM THE 200TH JUDICIAL DISTRICT COURT,
TRAVIS COUNTY, TEXAS, HON. TIM SULAK, PRESIDING

UNOPPOSED MOTION REQUESTING EXTENSION OF TIME
TO FILE APPELLEES’ BRIEF
______________________________________________________________

TO THE HONORABLE THIRD COURT OF APPEALS:

Come now Appellees Diana D. et al. and submit this Motion For Extension

of Time to File Appellees’ Brief as follows.

1) Appellees’ Brief regarding the interlocutory appeal of the trial court’s grant

of a temporary injunction is due on December 2, 2015. Appellees are requesting a

thirty day extension of time to file Appellees’ Brief, which would make the brief
due on January 1, 2016. Appellees have not previously requested an extension of

time to file their brief.

2) Good cause exists for allowing Appellees additional time to file their Brief.

The parties have agreed to mediate this case in December. Appellees seek an

extension of time to permit the parties to mediate the case without incurring

additional litigation expenses involved with preparation of a brief in this matter in

the event that mediation is successful. The parties will inform the court of the

results of mediation.

3) This motion is not sought for delay but so that justice may be served.

Wherefore, Appellees pray that the Court grant their thirty day extension

request to file their Brief to January 1, 2016, and for such other relief to which they

may be entitled.

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 Respectfully submitted,

RICHARDS RODRIGUEZ & SKEITH, LLP
816 Congress Avenue, Suite 1200
Austin, Texas 78701
Telephone: 512-476-0005
Facsimile: 512-476-1513

By: /s/ Daniel R. Richards_____________
DANIEL R. RICHARDS
State Bar No. 00791520
drichards@rrsfirm.com
BENJAMIN H. HATHAWAY
State Bar No. 09224500
bhathaway@rrsfirm.com
CLARK RICHARDS
State Bar No. 90001613
crichards@rrsfirm.com
CHASE C. HAMILTON
State Bar No. 24059881
chamilton@rrsfirm.com

ATTORNEYS FOR APPELLEES

CERTIFICATE OF CONFERENCE

Pursuant to Tex. App. R. 10.1(a)(5), I hereby certify that I have conferred
with counsel for Appellants and Appellants do not oppose a thirty day extension of
the deadline.

/s/ Daniel R. Richards_____________
DANIEL R. RICHARDS

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 CERTIFICATE OF SERVICE

I hereby certify that the foregoing document has been delivered to the
following counsel of records on this, the 20th day of November 2015 by electronic
notification and e-mail:

Kristofer S. Monson
Assistant Solicitor General
Office of the Attorney General of Texas
P.O. Box 12548, (MC 059)
Austin, Texas 78711-2548
Kristofer.monson@texasattorneygeneral.gov

/s/ Daniel R. Richards_____________
DANIEL R. RICHARDS

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