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 6/23/2025 3:09 PM NO. 15-25-00061-CV CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS IN THE COURT OF APPEALS AUSTIN, TEXAS FOR THE FIFTEENTH JUDICIAL DISTRICT OF TEXAS 6/23/2025 3:09:10 PM AT AUSTIN, TEXAS CHRISTOPHER A. PRINE Clerk FRANCESCA OKONKWO, ADMINISTRATIVE LAW JUDGE, TEXAS DEPARTMENT OF INSURANCE, DIVISION OF WORKERS’ COMPENSATION, IN HER OFFICIAL CAPACITY AND FORT BEND COUNTY.

Appellants VS. JOSHUA DAVID HEILIGER, INDIVIDUALLY, AND ON BEHALF OF THE ESTATE OF LAUREN BRITANNE 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 ORIGINALLY FROM THE 11TH JUDICIAL DISTRICT COURT OF HARRIS COUNTY, TEXAS CAUSE NO. 2024-78536; HONORABLE KRISTEN BRAUCHLE HAWKINS

APPELLEE’S FIRST UNOPPOSED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF

TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Appellee, Joshua David Heiliger, individually, and on behalf of the estate of Lauren Britanne Smith, deceased, and on behalf of death benefits beneficiaries Joshua David Heiliger and Emma Destiny Heiliger, requesting the Court to extend time to file its Appellee’s Brief and would respectfully show the Court as follows: REQUEST FOR EXTENSION OF TIME TO FILE BRIEF 1. Appellee’s Brief in this matter is currently due on or before July 3, 2025. Counsel for Appellee respectfully requests a 60-day extension to complete this brief, until Monday, September 1, 2025.

2. No party is opposed to this motion.

3. Appellee’s counsel needs additional time to file its brief as the original twenty-day timeline will be insufficient to research and draft Appellee’s Brief. As additional cause for this extension, Plaintiff’s counsel has a myriad of scheduled hearings in District Court cases, mediations and expert depositions, as well as 200+ commercial property tax protest hearings scheduled during the month of June and July, in multiple counties, around the Austin, Houston, and Dallas areas which also require travel.

4. Additionally, this Court has also requested responsive briefing in an original Writ of Mandamus proceeding involving the same parties pending before the Court, filed by Appellant Fort Bend County, under Cause No. 15-25-00102. Appellee’s brief in the related matter is also due to this Court on or before July 3, 2025.1 5. Appellant Francesca Okonkwo, and Appellee Greater Houston Psychiatric Associates, PLLC, indicated via counsel, they were unopposed to this motion. Appellant Fort Bend County agreed to this motion for extension but only agreed to a 45-day extension.

6. The Court has authority under Texas Rules of Appellate Procedure, Rule 38.6(d) to extend the time to file Appellee’s responsive brief.

7. This is Appellee Heiliger's first motion for extension to file its brief.

Appellee will also be requesting a 20-day extension to file its responsive Brief in Cause No. 15-25-00102.

8. Appellee respectfully requests a 60-day extension to the filing of its Brief in this cause from July 3, 2025, to September 1, 2025.

9. This motion is not sought for the sole purpose of delay, but to allow counsel sufficient time to adequately finalize and file Appellee’s responsive brief to fully address the issues raised in the instant appeal by Appellants’ in their separate briefs submitted to this Court and the Petition for Writ of Mandamus filed by Fort Bend County in a separate original proceeding involving the same parties.

PRAYER 10. ACCORDINGLY, Appellee, Joshua David Heiliger, Individually, And On Behalf Of The Estate Of Lauren Britanne Smith, Deceased And On Behalf Of Death Benefits Beneficiaries Joshua David Heiliger And Emma Destiny Heiliger respectfully request the Court to grant its First Unopposed Motion to Extend Time to File Appellee’s Brief and the deadline to be September 1, 2025.

Respectfully Submitted, /s/ Russell L. Morris Russell L. Morris State Bar No. 24099150 Pablo A. Franco State Bar No. 24121625 MCBRYDE FRANCO, PLLC 11000 Richmond Avenue, Suite 350 Houston, TX 77042 (713) 223-7699 (512) 691-9072 [facsimile] [email protected]

ATTORNEYS FOR APPELLEE JOSHUA DAVID HEILIGER, ET AL.

CERTIFICATE OF CONFERENCE I certify that I have conferred with counsel of record, Lisa Teachey, James Brazell, and LaVergne Chang, on or about June 17, 2025, through email exchange. Fort Bend County agreed to a 45-day extension, whereas Appellant Okonkwo and Appellee Greater Houston Psychiatric Association stated they were unopposed with the motion.

/s/ Russell Morris Russell Morris CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument was served on all counsel of record via the Court’s electronic Filing System and/or email, pursuant to Rule 21a of the Texas Rules of Civil Procedure on June 23, 2025.

VIA EFILE/ESERVE Dean G. Pappas State Bar No. 15454375 [email protected] Mary M. Markantonis State Bar No.12986800 [email protected] Lisa M. Teachey State Bar No. 24056416 [email protected] Marilyn J. Allen State Bar No. 24025225 [email protected] 8588 Katy Freeway, Suite 100 Houston, Texas 77024 713-914-6200-Telephone 713-914-6201-Facsimile ATTORNEY FOR INTERVENOR FORT BEND COUNTY VIA EFILE/ESERVE James Z. Brazell Sherlyn Harper State Bar No. 02930100 State Bar No. 24093176 Assistant Attorney General Assistant Attorney General Administrative Law Division Administrative Law Division Office Of The Attorney General Of Texas Office Of The Attorney General Of Texas P.O. Box 12548, Capitol Station 808 Travis Street, #1520 Austin, Texas 78711-2548 Houston, Texas 77002 Telephone: (512) 475-3204 Telephone: (713) 225-8913 Facsimile: (512) 320-0167 Facsimile: (512) 320-0167 [email protected] [email protected] ATTORNEYS FOR RESPONDENT, FRANCISCA OKONKWO, ADMINISTRATIVE LAW JUDGE, TEXAS DEPARTMENT OF INSURANCE, DIVISION OF WORKERS’ COMPENSATION, IN HER OFFICIAL AND INDIVIDUAL CAPACITIES VIA EFILE/ESERVE LaVerne Chang State Bar No. 00783819 [email protected] Cardwell & Chang, PLLC Lovett Blvd. Houston, TX 77006 Telephone: 713-222-6025 Facsimile: 713-222-0938 ATTORNEYS FOR RESPONDENT, GREATER HOUSTON PSYCHIATRIC ASSOCIATES, PLLC

/s/ Russell L. Morris Russell L. Morris 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.

Shauna O'Brien on behalf of Russell Morris Bar No. 24099150 [email protected] Envelope ID: 102313611 Filing Code Description: Motion Filing Description: Appellees First Unopposed Motion to Extend Time to File Brief Status as of 6/23/2025 4:22 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Lisa Teachey 24056416 [email protected] 6/23/2025 3:09:10 PM SENT Laverne Chang 783819 [email protected] 6/23/2025 3:09:10 PM SENT Marilyn Allen 24025225 [email protected] 6/23/2025 3:09:10 PM SENT Mary Markantonis 12986800 [email protected] 6/23/2025 3:09:10 PM SENT Dean Pappas 15454375 [email protected] 6/23/2025 3:09:10 PM SENT Andrew Bruce 24113627 [email protected] 6/23/2025 3:09:10 PM SENT Russell Morris 24099150 [email protected] 6/23/2025 3:09:10 PM SENT Hope Burnett-Furlow [email protected] 6/23/2025 3:09:10 PM SENT Pablo Franco 24121625 [email protected] 6/23/2025 3:09:10 PM SENT Catherine Hughes [email protected] 6/23/2025 3:09:10 PM SENT Sherlyn Harper [email protected] 6/23/2025 3:09:10 PM SENT James Z.Brazell [email protected] 6/23/2025 3:09:10 PM SENT Meridith Fischer [email protected] 6/23/2025 3:09:10 PM SENT