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
8340742
THIRD COURT OF APPEALS
AUSTIN, TEXAS
12/22/2015 11:38:21 AM
JEFFREY D. KYLE
CLERK
NO. 03-15-00657-CV

FILED IN
3rd COURT OF APPEALS
IN THE AUSTIN, TEXAS
THIRD COURT OF APPEALS 12/22/2015 11:38:21 AM
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

SECOND 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 January 4, 2015. Appellees are requesting a
thirty day extension of time to file Appellees’ Brief, which would make the brief

due on February 3, 2016.

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

The parties have agreed to mediate this case and the Court has previously granted

an extension of time to permit the parties to mediate the case. The parties are still

planning to mediate, however due to the holiday schedule the parties will not be

able to conduct the mediation prior to the current due date of Appellees’ brief.

Appellees request an extension of time to file their brief to avoid incurring

additional expense involved with preparation of the brief in the event that

mediation is successful. Appellants’ do not oppose this request.

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 February 3, 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 22nd day of December 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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