Francisca Okonkwo, Administrative Law Judge, Texas Department of Insurance, Division of Workers' Compensation, in Her Official Capacity and Fort Bend County v. Joshua David Heiliger, Individually, and on Behalf of the Estate of Lauren Brittane Smith, and on Behalf of Death Benefits Beneficiaries Joshua David Heiliger and Emma Destiny Heiliger

ACCEPTED 15-25-00061-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 5/29/2025 11:14 AM NO. 15-25-00061-CV CHRISTOPHER A. PRINE CLERK IN THE FIFTEENTH COURT OF APPEALS FILED IN AUSTIN, TEXAS 15th COURT OF APPEALS _______________________________________ AUSTIN, TEXAS 5/29/2025 11:14:20 AM FRANCISCA OKONKWO, ADMINISTRATIVE LAW JUDGE, TEXAS DEPARTMENT CHRISTOPHER A. PRINE OF INSURANCE, DIVISION OF WORKERS’ COMPENSATION, IN HER Clerk OFFICIAL CAPACITY AND FORT BEND COUNTY, Appellants, v. JOSHUA DAVID HEILIGER, INDIVIDUALLY, AND ON BEHALF OF THE ESTATE OF LAUREN BRITTANE SMITH, DECEASED, AND ON BEHALF OF DEATH BENEFITS BENEFICIARIES JOSHUA DAVID HEILIGER AND EMMA DESTINY HEILIGER AND GREATER HOUSTON PSYCHIATRIC ASSOCIATES, PLLC, Appellees. _______________________________________ On Appeal from the 11th Judicial District Court, Houston, Texas Cause No. 2024-78536 _______________________________________ UNOPPOSED MOTION TO EXTEND DEADLINE TO FILE APPELLANT ALJ OKONKWO’S BRIEF _______________________________________ Dated: May 29, 2025 TO THE HONORABLE JUSTICES OF THE FIFTEENTH COURT OF APPEALS: Appellant Francisca Okonkwo, Administrative Law Judge, Texas Department of Insurance, Division of Workers’ Compensation, in her Official Capacity (“Appellant ALJ Okonkwo”) respectfully moves this Court for an extension of the deadline for filing Appellant’s brief. In support, Appellant ALJ Okonkwo shows as follows: 1. Appellants’ briefs are currently due Tuesday, June 3, 2025. Counsel for Appellant ALJ Okonkwo requests a ten-day extension to complete this brief, until Friday, June 13, 2025.

2. Counsel for Appellant ALJ Okonkwo seeks additional time because he has been occupied with preparation on an accelerated timeline for and participation in a two-day hearing in Travis County District Court.

3. Counsel for Appellant ALJ Okonkwo requires a brief extension to finalize Appellant ALJ Okonkwo’s brief.

4. Counsel for Appellant ALJ Okonkwo has conferred with counsel for Appellant Fort Bend County, counsel for Appellee Joshua David Heiliger, Individually, and on behalf of the Estate of Lauren Brittane Smith, Deceased, and on behalf of Death Benefits Beneficiaries Joshua David Heiliger and Emma Destiny Heiliger, and counsel for Appellee Greater Houston Psychiatric Associates, PLLC about this motion, and all are unopposed.

5. Appellant ALJ Okonkwo has agreed to extend the deadline for Appellee Joshua David Heiliger, Individually, and on behalf of the Estate of Lauren Brittane Smith, Deceased, and on behalf of Death Benefits Beneficiaries Joshua David Heiliger and Emma Destiny Heiliger, and Appellee Greater Houston Psychiatric Associates, PLLC to file their Appellee Briefs to Monday, July 14, 2025.

6. Appellant ALJ Okonkwo moves for this extension not to delay proceedings but to allow her counsel sufficient time to adequately finalize and file ALJ Okonkwo’s brief to fully address the issues found in the instant appeal. This is Appellant ALJ Okonkwo’s first request for extension of time.

ACCORDINGLY, Appellant Francisca Okonkwo, Administrative Law Judge, Texas Department of Insurance, Division of Workers’ Compensation, in her Official Capacity respectfully requests an extension of time to and including Friday, June 13, 2025, to file and serve her brief.

UNOPPOSED MOTION TO EXTEND DEADLINE TO FILE APPELLANT ALJ OKONKWO’S BRIEF No. 15-25-00061-CV; Okonkwo, et al. v. Heiliger, et al. 2 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/ James Brazell JAMES Z. BRAZELL State Bar No. 02930100 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) 475-3204 Facsimile: (512) 320-0167 [email protected] ATTORNEYS FOR APPELLANT FRANCISCA OKONKWO, ADMINISTRATIVE LAW JUDGE, TEXAS DEPARTMENT OF INSURANCE, DIVISION OF WORKERS’ COMPENSATION, IN HER OFFICIAL CAPACITY

UNOPPOSED MOTION TO EXTEND DEADLINE TO FILE APPELLANT ALJ OKONKWO’S BRIEF No. 15-25-00061-CV; Okonkwo, et al. v. Heiliger, et al. 3 CERTIFICATE OF CONFERENCE On May 29, 2025, the undersigned conferred with counsel for Appellant Fort Bend County, counsel for Appellee Joshua David Heiliger, Individually, and on behalf of the Estate of Lauren Brittane Smith, Deceased, and on behalf of Death Benefits Beneficiaries Joshua David Heiliger and Emma Destiny Heiliger, and counsel for Appellee Greater Houston Psychiatric Associates, PLLC, and all parties are unopposed to this motion.

/s/ James Brazell JAMES Z. BRAZELL Assistant Attorney General

UNOPPOSED MOTION TO EXTEND DEADLINE TO FILE APPELLANT ALJ OKONKWO’S BRIEF No. 15-25-00061-CV; Okonkwo, et al. v. Heiliger, et al. 4 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and forgoing document has been served on the 29th day of May 2025 upon the following: DEAN G. PAPPAS RUSSELL L. MORRIS State Bar No. 15454375 State Bar No. 24099150 MARY M. MARKANTONIS ANDREW W. BRUCE State Bar No. 12986800 State Bar No. 24113627 LISA M. TEACHEY PABLO A. FRANCO State Bar No. 24056416 State Bar No. 24121625 MARILYN J. ALLEN MCBRYDE FRANCO, PLLC State Bar No. 24025225 11000 Richmond Avenue, Suite 350 DEAN G. PAPPAS LAW FIRM, PLLC Houston, Texas 77042 8588 Katy Freeway, Suite 100 Telephone: (713) 223-7699 Houston, Texas 77024 Facsimile: (512) 691-9072 Telephone: (713) 914-6200 [email protected] Facsimile: (713) 914-6201 [email protected] [email protected] [email protected] [email protected] [email protected] ATTORNEYS FOR APPELLEE HEILIGER [email protected] ATTORNEYS FOR APPELLANT FORT BEND COUNTY

LAVERNE CHANG State Bar No. 00783819 CARDWELL & CHANG, PLLC Lovett Blvd. Houston, Texas 77006 Telephone: (713) 222-6025 [email protected] ATTORNEY FOR APPELLEE GREATER HOUSTON PSYCHIATRIC ASSOCIATES, PLLC

/s/ James Brazell JAMES Z. BRAZELL Assistant Attorney General

UNOPPOSED MOTION TO EXTEND DEADLINE TO FILE APPELLANT ALJ OKONKWO’S BRIEF No. 15-25-00061-CV; Okonkwo, et al. v. Heiliger, et al. 5 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.

Meridith Fischer on behalf of James Brazell Bar No. 2930100 [email protected] Envelope ID: 101377147 Filing Code Description: Motion Filing Description: Unopposed Motion to Extend Deadline to File Appellant's Brief Status as of 5/29/2025 11:21 AM CST Associated Case Party: Fort Bend County Name BarNumber Email TimestampSubmitted Status Lisa Teachey 24056416 [email protected] 5/29/2025 11:14:20 AM SENT Marilyn Allen 24025225 [email protected] 5/29/2025 11:14:20 AM SENT Mary Markantonis 12986800 [email protected] 5/29/2025 11:14:20 AM SENT Dean Pappas 15454375 [email protected] 5/29/2025 11:14:20 AM SENT

Associated Case Party: Greater Houston Psychiatric Associates, PLLC Name BarNumber Email TimestampSubmitted Status Laverne Chang 783819 [email protected] 5/29/2025 11:14:20 AM SENT

Associated Case Party: JoshuaDavidHeiliger Name BarNumber Email TimestampSubmitted Status Andrew Bruce 24113627 [email protected] 5/29/2025 11:14:20 AM SENT Russell Morris 24099150 [email protected] 5/29/2025 11:14:20 AM SENT Pablo Franco 24121625 [email protected] 5/29/2025 11:14:20 AM SENT

Case Contacts Name BarNumber Email TimestampSubmitted Status Hope Burnett-Furlow [email protected] 5/29/2025 11:14:20 AM SENT

Associated Case Party: Francisca Okonkwo, ALJ, TDI-DWC 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.

Meridith Fischer on behalf of James Brazell Bar No. 2930100 [email protected] Envelope ID: 101377147 Filing Code Description: Motion Filing Description: Unopposed Motion to Extend Deadline to File Appellant's Brief Status as of 5/29/2025 11:21 AM CST Associated Case Party: Francisca Okonkwo, ALJ, TDI-DWC Name BarNumber Email TimestampSubmitted Status Catherine Hughes [email protected] 5/29/2025 11:14:20 AM SENT Sherlyn Harper [email protected] 5/29/2025 11:14:20 AM SENT James Z.Brazell [email protected] 5/29/2025 11:14:20 AM SENT Meridith Fischer [email protected] 5/29/2025 11:14:20 AM SENT