Edith Okechukwu Omietimi v. Texas Board of Nursing

ACCEPTED 15-25-00033-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 7/25/2025 11:34 AM CASE NO. 15-25-00033-CV CHRISTOPHER A. PRINE __________________________________________________________________ CLERK FILED IN 15th COURT OF APPEALS IN THE COURT OF APPEALS AUSTIN, TEXAS FOR THE FIFTEENTH DISTRICT OF TEXAS AT AUSTIN 7/25/2025 11:34:54 AM __________________________________________________________________ CHRISTOPHER A. PRINE Clerk EDITH OKECHUKWU OMIETIMI, Appellant, v. TEXAS BOARD OF NURSING, Appellee. __________________________________________________________________ APPELLEE TEXAS BOARD OF NURSING’S SECOND OPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF __________________________________________________________________ TO THE HONORABLE FIFTEENTH COURT OF APPEALS: In accordance with Texas Rules of Appellate Procedure 10.5(b) and 38.6(d) Appellee Texas Board of Nursing (BON) respectfully requests a 30-day extension of time to file its Appellee brief. In support of the motion, Appellee BON would show the following: 1. The deadline for filing Appellee’s brief is currently July 28, 2025.

2nd Motion for Extension of Time Page 1 of 4 2. Appellee BON requests a 30-day extension from the current deadline to file Appellee’s brief. If granted, this extension would cause Appellee’s brief to be due on August 27, 2025.

3. This extension is not sought for delay. Counsel for Appellee BON requires an extension due to multiple competing deadlines.

Specifically, counsel has a petition for review deadline on August 6, 2025 before the Texas Supreme Court, and an oral argument before the Texas Supreme Court on September 9, 2025. Factoring in the multiple levels of internal review required at the Office of the Attorney General, Counsel for Appellee will need an extension in order to present an effective brief to the Court and meet her other deadlines. Counsel for Appellant Omietimi opposes the requested extension.

4. One previous motion for extension of time to file Appellee’s brief has been filed and granted.

WHEREFORE, PREMISES CONSIDERED, Appellee BON respectfully requests that this honorable Court grant its motion for extension of time.

Respectfully submitted,

2nd Motion for Extension of Time Page 2 of 4 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/Kathy Johnson KATHY JOHNSON Assistant Attorney General Texas State Bar No. 24126964 Office of the Attorney General Administrative Law Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Telephone: (512) 475-4164 Facsimile: (512) 320-0167 [email protected] ATTORNEY FOR APPELLEE TEXAS BOARD OF NURSING

2nd Motion for Extension of Time Page 3 of 4 CERTIFICATE OF CONFERENCE I hereby certify that I have conferred with Marc Meyer, counsel for Appellant Edith Okechukwu Omietimi, by email on July 17, 2025.

Appellant opposes the granting of the relief requested in this Motion for Extension of Time.

/s/Kathy Johnson KATHY JOHNSON ASSISTANT ATTORNEY GENERAL CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing motion was served on the following counsel of record for Appellant Edith Okechukwu Omietimi by electronic service and/or e-mail on July 25, 2025: Marc Meyer SBN 24070266 2300 Woodforest Pkwy N. Suite 600 Montgomery, TX 77316 Phone: (281) 259-7575 [email protected] ATTORNEY FOR APPELLANT EDITH OKECHUKWU OMIETIMI

/s/Kathy Johnson KATHY JOHNSON ASSISTANT ATTORNEY GENERAL 2nd Motion for Extension of Time Page 4 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.

Christian Young on behalf of Kathy Johnson Bar No. 24126964 [email protected] Envelope ID: 103591551 Filing Code Description: Motion Filing Description: BON's 2nd Opposed MET re Brief Status as of 7/25/2025 12:12 PM CST Associated Case Party: EdithOkechukwuOmietimi Name BarNumber Email TimestampSubmitted Status Marc Meyer [email protected] 7/25/2025 11:34:54 AM SENT Sandra Thornton [email protected] 7/25/2025 11:34:54 AM SENT

Case Contacts Name BarNumber Email TimestampSubmitted Status John Vanderford 24086670 [email protected] 7/25/2025 11:34:54 AM SENT Katherine Johnson 24126964 [email protected] 7/25/2025 11:34:54 AM SENT

Associated Case Party: Texas Board of Nursing Name BarNumber Email TimestampSubmitted Status Christian Young [email protected] 7/25/2025 11:34:54 AM SENT Kathy Johnson [email protected] 7/25/2025 11:34:54 AM SENT