In the Guardianship of Landen Thomas Griswold, an Incapacitated Person v. the State of Texas

ACCEPTED 15-25-00017-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 5/14/2025 4:14 PM No. 15−25−00017−CV CHRISTOPHER A. PRINE CLERK FILED IN In the Fifteenth Court of Appeals 15th COURT OF APPEALS AUSTIN, TEXAS Austin, Texas 5/14/2025 4:14:24 PM CHRISTOPHER A. PRINE Clerk In the Guardianship of Landen Thomas Griswold, An Incapacitated Person ________________________________________________________ On Appeal from Cause No. G00074 County Court at Law Cherokee County, Texas

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF

Pursuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), Appellee, Texas Health and Humas Services Commission (Appellee) files this unopposed motion seeking a 2−week extension of time to file Appellee’s Brief to June 9, 2025.

In support of this motion, Appellee shows the following: 1. Appellee’s Brief is currently due May 27, 2025.

2. The following grounds provide good cause for extending the time to file Appellee’s Brief. Appellee’s former lead counsel, Reed Arroyo, has accepted another position outside of the Texas Office of the Attorney General—his last day with the Texas Office of the Attorney General was May 9, 2025. Appellee’s new and current lead counsel, Terri M. Abernathy, was substituted for Mr. Arroyo on May 9,

2025. Due to Ms. Abernathy’s other responsibilities in separate litigation matters, she was only able to meet and confer with Mr. Arroyo for the first time regarding this case on May 9, 2025. Consequently, Ms. Abernathy requires more time to review the filings and to prepare Appellee’s brief.

3. This is the third request for an extension of time to file Appellee’s Brief before this Court.

4. The motion is unopposed.

5. This motion is not filed for the purpose of delay, nor will Appellant be harmed and Appellant is unopposed to this extension request.

Prayer For these reasons, Appellee respectfully request that the Court grant an extension of time of 2−weeks to file Appellee’s Brief to June 9, 2025, and grant it any other relief to which it may be justly entitled.

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/ Terri M. Abernathy __________________________________ TERRI M. ABERNATHY Attorney-in-Charge Assistant Attorney General Texas State Bar No. 24062894 OFFICE OF THE ATTORNEY GENERAL OF TEXAS General Litigation Division P. O. Box 12548, Capitol Station Austin, Texas 78711−2548 Phone (512) 936−0562 Division Fax (512) 320−0667 Email [email protected] Counsel for Appellee Texas Health and Human Services Commission

CERTIFICATE OF CONFERENCE On May 13−14, 2025, the undersigned conferred with lead counsel for Appellant, who stated they are unopposed to the relief requested.

/s/ Terri M. Abernathy __________________________________ TERRI M. ABERNATHY Assistant Attorney General

CERTIFICATE OF SERVICE I certify that on May 14, 2025, a true and correct copy of this document was filed via the court’s e−filing system, causing electronic service upon all counsel of record in accordance with the Federal Rules of Civil Procedure as follows:

Tracia Y. Lee [email protected] Laurel M. Smith [email protected] Kean | Miller, LLP Pennzoil South Tower Louisiana Street, Suite 1800 South Tower Houston, Texas 77002 Phone (713) 844−3062 [email protected] Counsel for Appellee

/s/ Terri M. Abernathy __________________________________ TERRI M. ABERNATHY 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.

Quennette Rose on behalf of Terri Abernathy Bar No. 24062894 [email protected] Envelope ID: 100844031 Filing Code Description: Motion Filing Description: 20250514_HHSCs 3rd Unopposed MET Status as of 5/14/2025 4:57 PM CST Associated Case Party: Texas Health and Human Services Commission Name BarNumber Email TimestampSubmitted Status Jonathan Petix 24027728 [email protected] 5/14/2025 4:14:24 PM SENT Alyssa Bixby-Lawson 24122680 [email protected] 5/14/2025 4:14:24 PM SENT Terri Abernathy [email protected] 5/14/2025 4:14:24 PM SENT Quennette Rose [email protected] 5/14/2025 4:14:24 PM SENT Tristan AGarza [email protected] 5/14/2025 4:14:24 PM SENT Reed Arroyo [email protected] 5/14/2025 4:14:24 PM SENT

Associated Case Party: Candice Jeffcoat Name BarNumber Email TimestampSubmitted Status Tracia Lee [email protected] 5/14/2025 4:14:24 PM SENT