State Board of Social Worker Examiners v. Katherin Youniacutt and Tammy Thompson

4/25/2025 9:17 AM Velva L. Price District Clerk Travis County CAUSE NO. D-1-GN-24-009236 D-1-GN-24-009236 Rosa Oneal KATHERIN YOUNIACUTT and § IN THE DISTRICT COURT OF FILED IN TAMMY THOMPSON § 15th COURT OF APPEALS Plaintiffs, § AUSTIN, TEXAS § 4/25/2025 2:21:36 PM v. § TRAVISCHRISTOPHER COUNTY, TEXAS A. PRINE Clerk § TEXAS STATE BOARD OF SOCIAL § WORKER EXAMINERS, et. al., § § Defendants. § 345TH JUDICIAL DISTRICT NOTICE OF ACCELERATED INTERLOCUTORY APPEAL AND AUTOMATIC STAY Pursuant to Texas Rules of Appellate Procedure 25.1(a) and 26.1(b), Defendants, Texas State Board of Social Worker Examiners; Dolores Saenz-Davila, Katie Andrade, Korina Delapeña, Ryan Dollinger, Asia Rodgers, Lea Ann Tatum, and Jennifer Swords, in their official capacities as members of the Texas State Board of Social Worker Examiners; Texas Behavioral Health Executive Council (“TBHEC”); Darrel D. Spinks, in his official capacity as Executive Director of TBHEC; Gloria Canseco, John K. Bielamowicz, Mark E. Cartwright, Steven Hallbauer, Daniel W. Parrish, and Christopher S. Taylor, in their official capacities as members of TBHEC; and Brian C. Brumley and Quida J. Pryor, in their official capacities as members of both the Texas State Board of Social Worker Examiners and TBHEC (collectively, “Defendants”), give notice of an appeal of the court’s order on April 14, 2025 denying Defendants’ Plea to the Jurisdiction.

Defendants are entitled to an interlocutory appeal pursuant to Texas Civil Practice and Remedies Code section 51.014(a)(4) and (8), which allow for an immediate appeal from an order that denies a plea to the jurisdiction. Defendants appeal to the Fifteenth Court of Appeals. This is an accelerated appeal as provided by Texas Rules of Appellate Procedure 28.1. This is not a parental termination or child protection case, as defined in Rule 28.4.

Pursuant to Texas Civil Practice and Remedies Code § 51.014(b), all further proceedings in this court are stayed pending resolution of Defendants’ appeal. Pursuant to Section 6.001, as a governmental officers, Defendants are not required to file a bond for court costs. Defendants’ appeal is therefore perfected upon the filing of the notice of appeal.

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 for General Litigation Division

/s/ John Ramsey JOHN RAMSEY Attorney-in-Charge Texas State Bar No. 24051227 [email protected] ALI THORBURN Texas Bar No. 24125064 [email protected] Assistant Attorneys General General Litigation Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 (512) 463-2120 | FAX: (512) 320-0667 COUNSEL FOR DEFENDANTS

CERTIFICATE OF SERVICE I hereby certify that on April 25, 2025, a true and correct copy of the foregoing document was served via the electronic filing system to all counsel of record.

/s/ John Ramsey JOHN RAMSEY Assistant Attorney General

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.

Laura Hendrix on behalf of John Ramsey Bar No. 24051227 [email protected] Envelope ID: 100081552 Filing Code Description: Notice of Appeal Filing Description: NOTICE OF ACCELERATED INTERLOCUTORY APPEAL AND AUTOMATIC STAY Status as of 4/25/2025 11:32 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Arif Panju 24070380 [email protected] 4/25/2025 9:17:59 AM SENT James Knight [email protected] 4/25/2025 9:17:59 AM SENT Andrew Ward [email protected] 4/25/2025 9:17:59 AM SENT Ashlynn Acosta [email protected] 4/25/2025 9:17:59 AM SENT Claire Purple [email protected] 4/25/2025 9:17:59 AM SENT

Associated Case Party: TEXAS BEHAVIORAL HEALTH EXECUTIVE COUNCIL Name BarNumber Email TimestampSubmitted Status Laura Hendrix [email protected] 4/25/2025 9:17:59 AM SENT John Ramsey [email protected] 4/25/2025 9:17:59 AM SENT Ali Thorburn [email protected] 4/25/2025 9:17:59 AM SENT Ariana Ines [email protected] 4/25/2025 9:17:59 AM SENT