Texas Health and Human Services Commission v. Jessica Canto
Opinion
ACCEPTED 15-24-00080-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 5/21/2025 3:27 PM Case No. 15-24-00080-CV CHRISTOPHER A. PRINE CLERK In the Fifteenth District Court of Appeals at Austin, Texas FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS TEXAS HEALTH AND HUMAN SERVICES COMMISSION , 5/21/2025 3:27:32 PM CHRISTOPHER A. PRINE Appellant, Clerk v. JESSICA CANTO, Appellee.
On Appeal from the 200th District Court of Travis County, Texas The Honorable Jessica Mangrum, Presiding
AGREED MOTION TO CORRECT THE ADMINISTRATIVE RECORD
KEN PAXTON ROSALIND L. HUNT Attorney General of Texas State Bar No. 24067108 Assistant Attorney General BRENT WEBSTER Administrative Law Division First Assistant Attorney General Office of the Attorney General of Texas P.O. Box 12548, Capitol Station RALPH MOLINA Austin, Texas 78711-2548 Deputy First Assistant Attorney Telephone:(512) 475-4166 General [email protected] AUSTIN KINGHORN ATTORNEYS FOR APPELLANT Deputy Attorney General for Civil TEXAS HEALTH AND HUMAN SERVICES Litigation COMMISSION ERNEST C. GARCIA Chief, Administrative Law Division Appellant the Texas Health and Human Services Commission and Appellee Jessica Canto file this Agreed Motion to Correct the Administrative Record pursuant to Rule 36.3(a) of the Texas Rules of Appellate Procedure.
After the administrative record was filed with the Court of Appeals, the Appellant learned that the administrative record was incomplete.
Only the sealed portion of the record was filed on May 7, 2025, and the un-sealed portion of the record was missing.
The Notice of Filing of the Administrative Record stated that the record included two USB flash drives, containing: (1) a 363-page pdf document with sensitive data redacted as required by Texas Rule of Civil Procedure 21c; (2) The sealed record, including an Agreed Order Sealing Restricted Information, one audio file, eighteen video files, and one 168- page pdf document.
However, the Travis County district clerk’s office only received one USB flash drive. That flash drive contained the sealed portion of the record and was filed with the Court of Appeals. The parties now wish to supplement the administrative record with 363-page pdf document with sensitive data redacted as required by Texas Rule of Civil Procedure 21c.
All parties agree that this document should have been included in the record.
Page 2 of 4 Upon granting of this motion, Appellant will file a supplemental administrative record with the Travis County district clerk containing an official certification of the record and the 363-page pdf document.
PRAYER The parties respectfully request the Court to grant this motion to correct the administrative record and allow Appellant to supplement the record with 363-page pdf document.
Page 3 of 4 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 ERNEST C. GARCIA Chief, Administrative Law Division /s/ Rosalind L. Hunt______________ ROSALIND L. HUNT State Bar No. 24067108 Assistant Attorney General Administrative Law Division Office of the Attorney General of Texas P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Telephone: (512) 475-4166 [email protected] ATTORNEYS FOR APPELLANT TEXAS HEALTH AND HUMAN SERVICES COMMISSION
Page 4 of 4 CERTIFICATE OF CONFERENCE I hereby certify that on May 21, 2025, the undersigned counsel for Appellant conferred with counsel for Appellee and Appellee agrees and joins in the filing of this motion.
/s/ Rosalind L. Hunt______________ ROSALIND L. HUNT ATTORNEY FOR APPELLANT TEXAS HEALTH AND HUMAN SERVICES COMMISSION CERTIFICATE OF SERVICE I hereby certify that on May 21, 2025, a true and correct copy of the above and forgoing document has been served to the following party of record via electronic service and/or electronic mail: Kim Cox State Bar No. 04951500 Law Office of Kim A. Cox 4101 S. Alameda St. Corpus Christi, Texas 78411 (361) 883-3265 [email protected] ATTORNEY FOR APPELLEE
/s/ Rosalind L. Hunt_____________ ROSALIND L. HUNT ATTORNEY FOR APPELLANT TEXAS HEALTH AND HUMAN SERVICES COMMISSION
Page 5 of 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.
Jennifer Foster on behalf of Rosalind Hunt Bar No. 24067108 [email protected] Envelope ID: 101122313 Filing Code Description: Motion Filing Description: Agreed Motion to Correct the Administrative Record Status as of 5/21/2025 4:19 PM CST Associated Case Party: Tex Health & Human Services Comm Name BarNumber Email TimestampSubmitted Status Rosalind Hunt [email protected] 5/21/2025 3:27:32 PM SENT
Associated Case Party: Jessica Canto Name BarNumber Email TimestampSubmitted Status Pamela MWilliams [email protected] 5/21/2025 3:27:32 PM SENT
Case Contacts Name BarNumber Email TimestampSubmitted Status Jennifer Foster [email protected] 5/21/2025 3:27:32 PM SENT Kim Cox [email protected] 5/21/2025 3:27:32 PM ERROR
Case-law data current through December 31, 2025. Source: CourtListener bulk data.