Case Information
*0 FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS 5/14/2025 12:54:43 PM CHRISTOPHER A. PRINE Clerk *1 5/13/2025 3:07 PM Velva L. Price District Clerk Travis County D-1-GN-20-003118 CAUSE NO. D-1-GN-20-003118 Rosa Oneal JULIUS KADIA, § IN THE DISTRICT COURT
Plaintiff , §
§
v. § TRAVIS COUNTY, TEXAS
§
TEXAS HEALTH AND HUMAN §
SERVICES COMMISSION, §
Defendant. § 345TH JUDICIAL DISTRICT DEFENDANT TEXAS HEALTH AND HUMAN SERVICES COMMISSION’S NOTICE OF APPEAL OF FINAL JUDGMENT
Defendant Texas Health and Human Services Commission (“Defendant” or “HHSC”), hereby files this Notice of Appeal pursuant to Texas Civil Practice and Remedies Code section
51.012, appealing the Final Judgment signed on February 18, 2025.
1. On March 14, 2025, the Defendant timely filed its Motion for Remittitur and Motion for New Trial. On or about April 30, 2025, the Defendant’s Motion for New Trial was
overruled by operation of law. See Tex. R. Civ. Proc. 329b(c).
2. Defendant timely files this notice within 90 days after the date the judgment was signed, in accordance with Texas Rule of Appellate Procedure 26.1.
3. This Notice of Appeal is filed and served on all parties in the above titled and numbered cause in accordance with Texas Rule of Appellate Procedure 25.1.
4. Defendant respectfully notifies the Court that as a governmental unit, Defendant is not required to file a bond for court costs. See T EX . C IV . P RAC . & R EM . C ODE § 6.001.
Defendant’s appeal is therefore perfected upon the filing of the notice of appeal.
5. Defendant respectfully requests that the trial court clerk comply with the duties set forth in Texas Rules of Appellate Procedure 25.1(f), 35.1, and 35.3.
Dated: May 13, 2025 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
KIMBERLY GDULA Chief, General Litigation Division /s/ Stephanie A. Criscione DREW L. HARRIS Texas Bar No. 24057887 COLE P. WILSON
Texas Bar No. 24122856 STEPHANIE A. CRISCIONE Texas Bar No. 24109768 Assistant Attorneys General General Litigation Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Phone (512) 463-2120 Fax (512) 320-0667
drew.harris@oag.texas.gov cole.wilson@oag.texas.gov stephanie.criscione@oag.texas.gov COUNSEL FOR DEFENDANT 2 *3 CERTIFICATE OF SERVICE
I hereby certify that on May 13, 2025, a true and correct copy of the foregoing instrument has been served electronically through the electronic-filing manager to all registered parties in
compliance with TRCP 21a to:
Corinna Chandler
chandler@chandlerlawpc.com Tel: (972) 863-9063
Fax: (972) 692-5220
Eliot Shavin
eshavin@sbcglobal.net Tel: (214) 522-2010
CHANDLER & SHAVIN, PLLC
12377 Merit Drive, Suite 880
Dallas, Texas 75251
ATTORNEYS FOR PLAINTIFF
/s/ Stephanie A. Criscione Stephanie A. Criscione 3 *4 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.
Thomas Ray on behalf of Drew Harris
Bar No. 24057887
thomas.ray@oag.texas.gov
Envelope ID: 100781374
Filing Code Description: Notice of Appeal
Filing Description: DEFENDANT TEXAS HEALTH AND HUMAN
SERVICES COMMISSION’S NOTICE OF APPEAL OF FINAL
JUDGMENT
Status as of 5/14/2025 10:35 AM CST
Associated Case Party: TEXAS HEALTH AND HUMAN SERVICES COMMISSION
Name BarNumber Email TimestampSubmitted Status
Drew Harris drew.harris@oag.texas.gov 5/13/2025 3:07:45 PM SENT
Thomas Ray thomas.ray@oag.texas.gov 5/13/2025 3:07:45 PM SENT
Raymond Abarca Raymond.Abarca@oag.texas.gov 5/13/2025 3:07:45 PM SENT
Stephanie Criscione stephanie.criscione@oag.texas.gov 5/13/2025 3:07:45 PM SENT
Cole Wilson Cole.Wilson@oag.texas.gov 5/13/2025 3:07:45 PM SENT
Venessa Rodriguez Venessa.Rodriguez@oag.texas.gov 5/13/2025 3:07:45 PM SENT
Associated Case Party: JULIUS KADIA
Name BarNumber Email TimestampSubmitted Status
Corinna Chandler chandler@chandlerlawpc.com 5/13/2025 3:07:45 PM SENT
Eliot Shavin eshavin@sbcglobal.net 5/13/2025 3:07:45 PM SENT
Eliot Shavin shavin@chandlershavin.com 5/13/2025 3:07:45 PM SENT