Bright Health Management, Inc. v. Cantilo & Bennett, L.L.P., Special Deputy Receiver of Bright Healthcare Insurance Company of Texas

ACCEPTED 15-25-00092-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 7/21/2025 11:22 AM CHRISTOPHER A. PRINE NO. 15-25-00092-CV CLERK ______________________________________________FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS IN THE FIFTEENTH COURT OF APPEALS 7/21/2025 11:22:30 AM AUSTIN, TEXAS CHRISTOPHER A. PRINE ______________________________________________ Clerk BRIGHT HEALTH MANAGEMENT, INC. Appellant, V. CANTILO & BENNETT, LLP, SPECIAL DEPUTY RECEIVER FOR BRIGHT HEALTHCARE INSURANCE COMPANY OF TEXAS Appellee ___________________________________________ UNOPPOSED CONDITIONAL MOTION FOR EXTENSION ______________________________________________ This Court is currently considering whether there is appellate jurisdiction over this appeal. The Court expressed that it did not believe that there is jurisdiction and asked Appellant Bright Health Management (“BHM”) to provide briefing on the issue. BHM filed a pleading arguing that there is appellate jurisdiction, and Appellee Cantilo & Bennett, LLP, Special Deputy Receiver for Bright Healthcare Insurance Company of Texas (the “SDR”) filed a response arguing that there is no jurisdiction.

The jurisdiction issue is pending before the Court. But meanwhile, SDR’s Brief of Appellee is due today, July 21. If the Court determines that there is no appellate jurisdiction and dismisses this appeal, there would be no need for the SDR to file that brief. The SDR therefore asks that the Court grant an extension of time

4935-3584-1879 to file the Brief of Appellee until 20 days following the Court’s ruling on the pending jurisdiction issue. If the Court dismisses the appeal for lack of jurisdiction, the SDR will not need to file a brief. If the Court retains this appeal, then the SDR will file his Brief of Appellee within 20 days of the ruling.

Appellant BHM does not oppose the relief sought through this motion.

WHEREFORE, the SDR prays that the Court grant this motion and extend the time to file the Brief of Appellee until 20 days after the Court rules on the pending jurisdiction issue.

Respectfully submitted, By: _________ Jane Webre State Bar No. 21050060 [email protected] Scott Douglass & McConnico LLP Colorado Street, Suite 2400 Austin, TX 78701 Telephone: (512) 495-6300 Facsimile: (512) 495-6399 Gregory A. Pierce State Bar No. 15994250 P.O. Box 40 Austin, Texas 78767 Telephone: (512) 474-2154 [email protected] Attorneys for Appellee Cantilo & Bennett, L.L.P., Special Deputy Receiver of Bright Healthcare Insurance Company of Texas

4935-3584-1879 CERTIFICATE OF SERVICE I certify that this pleading was served on all counsel of record through the electronic filing system on July 21, 2025.

\s\ Jane Webre Jane Webre CERTIFICATE OF CONFERENCE I certify that on July 18, 2025, I communicated by e-mail with Carlos Soltero, counsel for Appellant BHM in this appeal. He informed me that BHM does not oppose the relief sought through this motion.

\s\ Jane Webre Jane Webre

4935-3584-1879 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.

Michaelle Peters on behalf of Jane Webre Bar No. 21050060 [email protected] Envelope ID: 103371102 Filing Code Description: Motion Filing Description: Unopposed Conditional Motion for Extension Status as of 7/21/2025 11:32 AM CST Associated Case Party: Cantilo & Bennett, LLP as Special Deputy Receiver for Bright Health Insurance Company of Texas Name BarNumber Email TimestampSubmitted Status Michaelle Peters [email protected] 7/21/2025 11:22:30 AM SENT Jane Webre [email protected] 7/21/2025 11:22:30 AM SENT Abril Rivera [email protected] 7/21/2025 11:22:30 AM SENT

Case Contacts Name BarNumber Email TimestampSubmitted Status Christopher Fuller 7515500 [email protected] 7/21/2025 11:22:30 AM SENT Gregory Pierce 15994250 [email protected] 7/21/2025 11:22:30 AM SENT Patricia Muniz [email protected] 7/21/2025 11:22:30 AM SENT Brian Falligant [email protected] 7/21/2025 11:22:30 AM SENT Rachael Padgett [email protected] 7/21/2025 11:22:30 AM SENT Lisa Alcantar [email protected] 7/21/2025 11:22:30 AM SENT Kayla RosePfeiffer [email protected] 7/21/2025 11:22:30 AM SENT Carlos R.Soltero [email protected] 7/21/2025 11:22:30 AM SENT Max Mendel [email protected] 7/21/2025 11:22:30 AM SENT Brytne Kitchin [email protected] 7/21/2025 11:22:30 AM SENT