*0 FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS 7/21/2025 11:22:30 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 15-25-00092-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 7/21/2025 11:22 AM CHRISTOPHER A. PRINE NO. 15-25-00092-CV CLERK ______________________________________________ IN THE FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS
______________________________________________ BRIGHT HEALTH MANAGEMENT, INC.
Appellant,
V.
CANTILO & BENNETT, LLP, SPECIAL DEPUTY RECEIVER FOR BRIGHT
HEALTHCARE INSURANCE COMPANY OF TEXAS Appellee
___________________________________________ UNOPPOSED CONDITIONAL MOTION FOR EXTENSION ______________________________________________ This Court is currently considering whether there is appellate jurisdiction over this appeal. The Court expressed that it did not believe that there is jurisdiction and
asked Appellant Bright Health Management (“BHM”) to provide briefing on the
issue. BHM filed a pleading arguing that there is appellate jurisdiction, and Appellee
Cantilo & Bennett, LLP, Special Deputy Receiver for Bright Healthcare Insurance
Company of Texas (the “SDR”) filed a response arguing that there is no jurisdiction.
The jurisdiction issue is pending before the Court. But meanwhile, SDR’s Brief of Appellee is due today, July 21. If the Court determines that there is no
appellate jurisdiction and dismisses this appeal, there would be no need for the SDR
to file that brief. The SDR therefore asks that the Court grant an extension of time
4935-3584-1879
to file the Brief of Appellee until 20 days following the Court’s ruling on the pending
jurisdiction issue. If the Court dismisses the appeal for lack of jurisdiction, the SDR
will not need to file a brief. If the Court retains this appeal, then the SDR will file
his Brief of Appellee within 20 days of the ruling.
Appellant BHM does not oppose the relief sought through this motion. WHEREFORE, the SDR prays that the Court grant this motion and extend the time to file the Brief of Appellee until 20 days after the Court rules on the pending
jurisdiction issue. Respectfully submitted,
By: _________
Jane Webre State Bar No. 21050060 jwebre@scottdoug.com
Scott Douglass & McConnico LLP 303 Colorado Street, Suite 2400 Austin, TX 78701
Telephone: (512) 495-6300 Facsimile: (512) 495-6399 Gregory A. Pierce
State Bar No. 15994250
P.O. Box 40
Austin, Texas 78767
Telephone: (512) 474-2154 gpierce@gpiercelaw.com Attorneys for Appellee
Cantilo & Bennett, L.L.P., Special Deputy Receiver of Bright Healthcare Insurance Company of Texas 2 4935-3584-1879
CERTIFICATE OF SERVICE I certify that this pleading was served on all counsel of record through the electronic filing system on July 21, 2025.
\s\ Jane Webre Jane Webre CERTIFICATE OF CONFERENCE I certify that on July 18, 2025, I communicated by e-mail with Carlos Soltero, counsel for Appellant BHM in this appeal. He informed me that BHM does not
oppose the relief sought through this motion.
\s\ Jane Webre Jane Webre 3 4935-3584-1879
Automated Certificate of eService This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Michaelle Peters on behalf of Jane Webre
Bar No. 21050060
mpeters@scottdoug.com
Envelope ID: 103371102
Filing Code Description: Motion
Filing Description: Unopposed Conditional Motion for Extension
Status as of 7/21/2025 11:32 AM CST
Associated Case Party: Cantilo & Bennett, LLP as Special Deputy Receiver for Bright
Health Insurance Company of Texas
Name BarNumber Email TimestampSubmitted Status
Michaelle Peters mpeters@scottdoug.com 7/21/2025 11:22:30 AM SENT
Jane Webre jwebre@scottdoug.com 7/21/2025 11:22:30 AM SENT
Abril Rivera arivera@scottdoug.com 7/21/2025 11:22:30 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Christopher Fuller 7515500 cfuller@fullerlaw.org 7/21/2025 11:22:30 AM SENT
Gregory Pierce 15994250 gpierce@gpiercelaw.com 7/21/2025 11:22:30 AM SENT
Patricia Muniz pmuniz@inquestresources.com 7/21/2025 11:22:30 AM SENT
Brian Falligant bfalligant@inquestresources.com 7/21/2025 11:22:30 AM SENT
Rachael Padgett rpadgett@maynardnexsen.com 7/21/2025 11:22:30 AM SENT
Lisa Alcantar lalcantar@maynardnexsen.com 7/21/2025 11:22:30 AM SENT
Kayla RosePfeiffer KPfeiffer@maynardnexsen.com 7/21/2025 11:22:30 AM SENT
Carlos R.Soltero CSoltero@MaynardNexsen.com 7/21/2025 11:22:30 AM SENT
Max Mendel mmendel@maynardnexsen.com 7/21/2025 11:22:30 AM SENT
Brytne Kitchin bkitchin@maynardnexsen.com 7/21/2025 11:22:30 AM SENT