15-25-00061-CV
Tex. App.
May 29, 2025

FRANCISCA OKONKWO, ADMINISTRATIVE LAW JUDGE, TEXAS DEPARTMENT OF INSURANCE, DIVISION OF WORKERS’ COMPENSATION, IN HER OFFICIAL CAPACITY AND FORT BEND COUNTY, Appellants, v. JOSHUA DAVID HEILIGER, INDIVIDUALLY, AND ON BEHALF OF THE ESTATE OF LAUREN BRITTANE SMITH, DECEASED, AND ON BEHALF OF DEATH BENEFITS BENEFICIARIES JOSHUA DAVID HEILIGER AND EMMA DESTINY HEILIGER AND GREATER HOUSTON PSYCHIATRIC ASSOCIATES, PLLC, Appellees.

NO. 15-25-00061-CV

IN THE FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS

On Appeal from the 11th Judicial District Court, Houston, Texas

Cause No. 2024-78536

UNOPPOSED MOTION TO EXTEND DEADLINE

TO FILE APPELLANT ALJ OKONKWO’S BRIEF

Dated: May 29, 2025

TO THE HONORABLE JUSTICES OF THE FIFTEENTH COURT OF APPEALS:

Appellant Francisca Okonkwo, Administrative Law Judge, Texas Department of Insurance, Division of Workers’ Compensation, in her Official Capacity (“Appellant ALJ Okonkwo”) respectfully moves this Court for an extension of the deadline for filing Appellant’s brief. In support, Appellant ALJ Okonkwo shows as follows:

1. Appellants’ briefs are currently due Tuesday, June 3, 2025. Counsel for Appellant ALJ Okonkwo requests a ten-day extension to complete this brief, until Friday, June 13, 2025.

2. Counsel for Appellant ALJ Okonkwo seeks additional time because he has been occupied with preparation on an accelerated timeline for and participation in a two-day hearing in Travis County District Court.

3. Counsel for Appellant ALJ Okonkwo requires a brief extension to finalize Appellant ALJ Okonkwo’s brief.

4. Counsel for Appellant ALJ Okonkwo has conferred with counsel for Appellant Fort Bend County, counsel for Appellee Joshua David Heiliger, Individually, and on behalf of the Estate of Lauren Brittane Smith, Deceased, and on behalf of Death Benefits Beneficiaries Joshua David Heiliger and Emma Destiny Heiliger, and counsel for Appellee Greater Houston Psychiatric Associates, PLLC about this motion, and all are unopposed.

5. Appellant ALJ Okonkwo has agreed to extend the deadline for Appellee Joshua David Heiliger, Individually, and on behalf of the Estate of Lauren Brittane Smith, Deceased, and on behalf of Death Benefits Beneficiaries Joshua David Heiliger and Emma Destiny Heiliger, and Appellee Greater Houston Psychiatric Associates, PLLC to file their Appellee Briefs to Monday, July 14, 2025.

6. Appellant ALJ Okonkwo moves for this extension not to delay proceedings but to allow her counsel sufficient time to adequately finalize and file ALJ Okonkwo’s brief to fully address the issues found in the instant appeal. This is Appellant ALJ Okonkwo’s first request for extension of time.

ACCORDINGLY, Appellant Francisca Okonkwo, Administrative Law Judge, Texas Department of Insurance, Division of Workers’ Compensation, in her Official Capacity respectfully requests an extension of time to and including Friday, June 13, 2025, to file and serve her brief.

Respectfully submitted,

KEN PAXTON

Attorney General of Texas

BRENT WEBSTER

First Assistant Attorney General

RALPH MOLINA

Deputy First Assistant Attorney General

AUSTIN KINGHORN

Deputy Attorney General for Civil Litigation

ERNEST C. GARCIA

Chief, Administrative Law Division

/s/ James Brazell

JAMES Z. BRAZELL

State Bar No. 02930100

Assistant Attorney General

Administrative Law Division

OFFICE OF THE ATTORNEY GENERAL OF TEXAS

P.O. Box 12548, Capitol Station

Austin, Texas 78711-2548

Telephone: (512) 475-3204

Facsimile: (512) 320-0167

James.Brazell@oag.texas.gov

ATTORNEYS FOR APPELLANT

FRANCISCA OKONKWO, ADMINISTRATIVE LAW JUDGE, TEXAS DEPARTMENT OF INSURANCE,

DIVISION OF WORKERS’ COMPENSATION, IN HER OFFICIAL CAPACITY

CERTIFICATE OF CONFERENCE

On May 29, 2025, the undersigned conferred with counsel for Appellant Fort Bend County, counsel for Appellee Joshua David Heiliger, Individually, and on behalf of the Estate of Lauren Brittane Smith, Deceased, and on behalf of Death Benefits Beneficiaries Joshua David Heiliger and Emma Destiny Heiliger, and counsel for Appellee Greater Houston Psychiatric Associates, PLLC, and all parties are unopposed to this motion.

/s/ James Brazell

JAMES Z. BRAZELL

Assistant Attorney General

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and forgoing document has been served on the 29th day of May 2025 upon the following:

DEAN G. PAPPAS
State Bar No. 15454375
MARY M. MARKANTONIS
State Bar No. 12986800
LISA M. TEACHEY
State Bar No. 24056416
MARILYN J. ALLEN
State Bar No. 24025225
DEAN G. PAPPAS LAW FIRM, PLLC
8588 Katy Freeway, Suite 100
Houston, Texas 77024
Telephone: (713) 914-6200
Facsimile: (713) 914-6201
dpappas@dgplawfirm.com
mmarkantonis@dgplawfirm.com
lteachey@dgplawfirm.com
mallen@dgplawfirm.com

ATTORNEYS FOR APPELLANT
FORT BEND COUNTY

LAVERNE CHANG
State Bar No. 00783819
CARDWELL & CHANG, PLLC
511 Lovett Blvd.
Houston, Texas 77006
Telephone: (713) 222-6025
Chang@cardwellchang.com

ATTORNEY FOR APPELLEE GREATER HOUSTON
PSYCHIATRIC ASSOCIATES, PLLC

RUSSELL L. MORRIS
State Bar No. 24099150
ANDREW W. BRUCE
State Bar No. 24113627
PABLO A. FRANCO
State Bar No. 24121625
MCBRYDE FRANCO, PLLC
11000 Richmond Avenue, Suite 350
Houston, Texas 77042
Telephone: (713) 223-7699
Facsimile: (512) 691-9072
Serv.russell@mf-txlaw.com
Serv.andrew@mf-txlaw.com
Serv.pablo@mf-txlaw.com

ATTORNEYS FOR APPELLEE HEILIGER

/s/ James Brazell
JAMES Z. BRAZELL
Assistant Attorney General