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 ( 2015 )

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. 2 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 3 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 4