Texas State Board of Social Worker Examiners v. Katherin Youniacutt and Tammy Thompson

ACCEPTED 15-25-00064-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 8/21/2025 3:33 PM No. 15-25-00064-CV CHRISTOPHER A. PRINE CLERK In the Court of Appeals 15th COURT FILED IN OF APPEALS for the Fifteenth Judicial District8/21/2025 3:33:13 PM AUSTIN, TEXAS

CHRISTOPHER A. PRINE Clerk Texas State Board of Social Worker Examiners, et al., Appellants, v. Katherin Youniacutt and Tammy Thompson, Appellees.

On Appeal from the 345th Judicial District Court, Travis County UNOPPOSED MOTION TO EXTEND TIME TO FILE APPELLANTS’ REPLY BRIEF Pursuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), Appellants move to extend the time to file their reply brief by 21 days, from the current deadline of August 27, 2025, to a proposed new deadline of September 17.

I.

Appellees filed their brief on August 7, 2025, making appellants’ reply brief due on August 27. Tex. R. App. P. 38.6(c). Appellants now request a 21-day extension of the time to file that brief, which would create a new deadline of September 17. This is Appellants’ first request for an extension of their reply brief deadline.

II.

This extension is not sought for delay but to accommodate the schedule of Appellants’ counsel, Beth Klusmann. Ms. Klusmann’s recent and upcoming deadlines include drafting or assisting with the follow briefs: (1) an amicus brief in Doe v. Planned Parenthood Federation of America, No. 23-11184, currently pending before the Fifth Circuit en banc and due September 3, 2025; and (2) a supplemental brief in National Horsemen’s Benevolent and Protective Association v. Black, No. 23- 10520, in the Fifth Circuit, currently due September 4, 2025. In addition, Ms. Klusmann will be assisting three colleagues prepare for oral argument in early September.

This extension is not sought for delay, and additional time to research and analyze the issues presented in this appeal will allow for a thorough and helpful reply brief. Appellees do not oppose this motion.

Prayer For the foregoing reasons, Appellants respectfully request that the Court grant them a 21-day extension to file their reply brief, creating a new deadline of September 17.

Respectfully submitted.

Ken Paxton William R. Peterson Attorney General of Texas Solicitor General Brent Webster /s/ Beth Klusmann First Assistant Attorney General Beth Klusmann Assistant Solicitor General Office of the Attorney General State Bar No. 24036918 P.O. Box 12548 (MC 059) [email protected] Austin, Texas 78711-2548 Tel.: (512) 936-1700 Fax: (512) 474-2697 Counsel for Appellants

Certificate of Conference I certify that on August 21, 2025, I conferred by email with James Knight, lead counsel for Appellees, and he does not oppose this motion. /s/ Beth Klusmann Beth Klusmann

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.

Nancy Villarreal on behalf of Beth Klusmann Bar No. 24036918 [email protected] Envelope ID: 104692215 Filing Code Description: Motion Filing Description: 2025 0821 Youniacutt Reply MET_Final Status as of 8/21/2025 3:41 PM CST Associated Case Party: Katherin Youniacutt and Tammy Thompson Name BarNumber Email TimestampSubmitted Status Arif Panju 24070380 [email protected] 8/21/2025 3:33:13 PM SENT James T. Knight II [email protected] 8/21/2025 3:33:13 PM SENT

Associated Case Party: Texas State Board of Social Workers Examiners, et al.

Name BarNumber Email TimestampSubmitted Status John Ramsey 24051227 [email protected] 8/21/2025 3:33:13 PM SENT Beth Klusmann [email protected] 8/21/2025 3:33:13 PM SENT Ali Thorburn 24125064 [email protected] 8/21/2025 3:33:13 PM SENT Eric Abels [email protected] 8/21/2025 3:33:13 PM SENT

Case Contacts Name BarNumber Email TimestampSubmitted Status Nancy Villarreal [email protected] 8/21/2025 3:33:13 PM SENT Andrew Ward [email protected] 8/21/2025 3:33:13 PM SENT Ashlynn Acosta [email protected] 8/21/2025 3:33:13 PM SENT Claire Purple [email protected] 8/21/2025 3:33:13 PM SENT