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, 03-15-00657-CV

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

03-15-00657-CV

| Tex. App. | Nov 20, 2015

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Case Information

*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 11/20/2015 1:27:51 PM JEFFREY D. KYLE Clerk NO. 03-15-00657-CV THIRD COURT OF APPEALS 11/20/2015 1:27:51 PM JEFFREY D. KYLE AUSTIN, TEXAS 03-15-00657-CV *1 ACCEPTED ^[7927127] CLERK

IN THE THIRD COURT OF APPEALS

AUSTIN, TEXAS CHRIS TRAYLOR, EXECUTIVE COMMISSIONER OF TEXAS HEALTH

AND HUMAN SERVICES COMMISSION AND THE TEXAS HEALTH

AND HUMAN SERVICES COMMISSION,

APPELLANTS

DIANA D., et al

APPELLEES ON APPEAL FROM THE 200 TH 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.

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_____________

D ANIEL R. R ICHARDS State Bar No. 00791520 drichards@rrsfirm.com B ENJAMIN H. H ATHAWAY State Bar No. 09224500 bhathaway@rrsfirm.com C LARK R ICHARDS State Bar No. 90001613 crichards@rrsfirm.com C HASE C. H AMILTON 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 *4 CERTIFICATE OF SERVICE

I hereby certify that the foregoing document has been delivered to the

following counsel of records on this, the 20 th 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