Texas Court of Appeals, 15th District, 2025

Richard M. Young, Jr. A/K/A Richard Young v. Texas Parks and Wildlife Department, John Silovsky as Wildlife Division Director of Texas Parks and Wildlife Department, and the State of Texas

Richard M. Young, Jr. A/K/A Richard Young v. Texas Parks and Wildlife Department, John Silovsky as Wildlife Division Director of Texas Parks and Wildlife Department, and the State of Texas
Texas Court of Appeals, 15th District · Decided May 1, 2025
Richard M. Young, Jr. A/K/A Richard Young v. Texas Parks and Wildlife Department, John Silovsky as Wildlife Division Director of Texas Parks and Wildlife Department, and the State of Texas

Opinion

ACCEPTED 15-24-00052-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 5/1/2025 1:16 PM No. 15-24-00052-CV CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS IN THE FIFTEENTH DISTRICT COURT OF APPEALS (AUSTIN ) TEXAS AUSTIN, 5/1/2025 1:16:07 PM CHRISTOPHER A. PRINE Clerk Richard M. YOUNG, Jr. a/k/a Richard Young, Appellant vs. TEXAS PARKS & WILDLIFE DEPARTMENT, et al., Appellees.

APPELLANT’S UNOPPOSED MOTION FOR EXTENSION TO FILE MOTION FOR PANEL REHEARING

To the Honorable Justices: This Court issued its Opinion in this case on April 24, 2025, making Appellant’s Motion for Rehearing due on May 9, 2025. Due to conflicting trial and appellate deadlines, in addition to pre-scheduled family commitments out of state,1 Appellant’s appellate counsel needs additional time to prepare the Motion for Rehearing. Appellant seeks 30 days extension, which, if granted, will make Appellant’s Motion for

For her children, during the next 10 days, the undersigned is traveling to both Florida (Pro Series Swim Meet, Fort Lauderdale), as well as Utah (South African Dorper Sheep Certification Seminar, Salt Lake City). Additionally, during the time period, the undersigned is preparing for a jury trial in Gillespie County (No. 16830, 216th District Court) and briefing in Hilton v. Gibbs, et al. (Sixth Court of Appeals).

Rehearing due on June 9, 2025. Appellees are unopposed to this extension request.

Respectfully submitted, Kimberly S. Keller KELLER STOLARCZYK PLLC W. Bandera Road No. 114-PMB 800 Boerne, Texas 78006 Tele: 830.981.5000 /s/Kimberly S. Keller Kimberly S. Keller SBN: 24014182 Email: [email protected] APPELLANT’S COUNSEL CERTIFICATE OF COMPLIANCE & SERVICE On today’s date, I conferred with opposing counsel (Ian Lancaster) who confirmed Appellees are unopposed to this Motion. Additionally, on this same date, I served, via this Court’s e-filing system, this Motion on those listed below: Counsel for Appellees: KEN PAXTON, Attorney General of Texas; BRENT WEBSTER, First Asst. Attorney General; JAMES LLOYD, Deputy Attorney General for Civil Litigation; KELLIE E. BILLINGS-RAY, Chief, Environmental Protection Division, OFFICE OF THE ATTORNEY GENERAL, Environmental Protection Division, P.O. Box 12548, MC066, Austin, Texas 78711-2548

IAN LANCASTER, Asst. Attorney General, Email: [email protected] H. CARL MYERS, Asst. Attorney General, Email: [email protected] HEATHER COFFEE, Asst. Attorney General, Email: [email protected] /s/Kimberly S. Keller Kimberly S. Keller

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.

Kimberly Keller on behalf of Kimberly Keller Bar No. 24014182 [email protected] Envelope ID: 100330939 Filing Code Description: Motion Filing Description: Unopposed Extension to File Motion for Rehearing Status as of 5/1/2025 1:25 PM CST Associated Case Party: State Of Texas Name BarNumber Email TimestampSubmitted Status Kellie E.Billings-Ray [email protected] 5/1/2025 1:16:07 PM SENT Ian Lancaster [email protected] 5/1/2025 1:16:07 PM SENT Laura Courtney [email protected] 5/1/2025 1:16:07 PM SENT H. CarlMyers [email protected] 5/1/2025 1:16:07 PM SENT James ScottMcCarley [email protected] 5/1/2025 1:16:07 PM SENT

Associated Case Party: Maurice E. "Pete" Moore, III, d/b/a Cypress Ranches Name BarNumber Email TimestampSubmitted Status Kevin Dubose [email protected] 5/1/2025 1:16:07 PM SENT Paul W.Green [email protected] 5/1/2025 1:16:07 PM SENT Latonya McPherson [email protected] 5/1/2025 1:16:07 PM SENT James T.Drakeley [email protected] 5/1/2025 1:16:07 PM SENT

Case Contacts Name BarNumber Email TimestampSubmitted Status Karen LWatkins [email protected] 5/1/2025 1:16:07 PM SENT C DixonMosty [email protected] 5/1/2025 1:16:07 PM SENT Richard Mosty [email protected] 5/1/2025 1:16:07 PM SENT Jennifer SRiggs [email protected] 5/1/2025 1:16:07 PM SENT Kimberly SKeller [email protected] 5/1/2025 1:16:07 PM SENT Clayton CUtkov [email protected] 5/1/2025 1:16:07 PM SENT

Case-law data current through December 31, 2025. Source: CourtListener bulk data.