Jorge R. Guevara, M.D. v. Texas Medical Board

ACCEPTED 15-25-00036-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 8/26/2025 7:32 AM CHRISTOPHER A. PRINE CASE NO. 15-25-00036-CV CLERK __________________________________________________________________ FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS IN THE COURT OF APPEALS 8/26/2025 7:32:45 AM FOR THE FIFTEENTH DISTRICT OF TEXAS AT AUSTIN A. PRINE CHRISTOPHER __________________________________________________________________ Clerk

JORGE R. GUEVARA, M.D., Appellant, v. TEXAS MEDICAL BOARD Appellee. __________________________________________________________________ APPELLEE TEXAS MEDICAL BOARD’S SECOND UNOPPOSED 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 the Texas Medical Board (TMB) respectfully requests a 30-day extension of time to file its brief. In support of the motion, Appellee TMB would show the following: 1. The deadline for filing Appellee’s brief is August 29, 2025.

2nd Unopposed Motion for Extension of Time Page 1 of 5 2. Appellee TMB requests a 30-day extension from the current deadline to file its brief. If granted, this extension would cause Appellee’s brief to be due on September 29, 2025.

3. Counsel for TMB requires an extension due to multiple competing deadlines. Between counsel’s first and second request for an extension of time, counsel has been preparing for her first oral argument before the Texas Supreme Court, submitted a petition for review to the Texas Supreme Court, provided general counsel services at three board meetings, drafted an appellate brief in Omietimi v. Texas Board of Nursing, Case No. 15-25-00033-CV, before the 15th Court of Appeals, and prepared for a hearing on the merits scheduled for August 27, 2025 before the 250th Judicial District of Travis County. She will need 30 more days to finish the brief in the above-captioned case.

4. Counsel for Appellant Dr. Guevara does not oppose the requested extension.

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

2nd Unopposed Motion for Extension of Time Page 2 of 5 WHEREFORE, PREMISES CONSIDERED, Appellee TMB respectfully requests that this honorable Court grant its motion for extension of time.

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/Kathy Johnson KATHY JOHNSON Assistant Attorney General Texas State Bar No. 24126964 Ted A. Ross Assistant Attorney General State Bar No. 24008890 Office of the Attorney General Administrative Law Division P.O. Box 12548, Capitol Station 2nd Unopposed Motion for Extension of Time Page 3 of 5 Austin, Texas 78711-2548 Telephone: (512) 475-4164 [email protected] ATTORNEYS FOR APPELLEE TEXAS MEDICAL BOARD

CERTIFICATE OF CONFERENCE I hereby certify that I have conferred with Hayley Ellison, counsel for Appellant Dr. Guevara, by email on August 25, 2025. Appellant does not oppose the granting of the relief requested in this motion.

/s/Kathy Johnson KATHY JOHNSON ASSISTANT ATTORNEY GENERAL

2nd Unopposed Motion for Extension of Time Page 4 of 5 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 by electronic service and/or e-mail on August 26, 2025: Hayley Ellison Davis & Santos, PLLC S. Flores St. San Antonio, TX 78204 P: 210-853-5882 [email protected] ATTORNEY FOR APPELLANT /s/Kathy Johnson KATHY JOHNSON ASSISTANT ATTORNEY GENERAL

2nd Unopposed Motion for Extension of Time Page 5 of 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.

Jeff Lutz on behalf of Kathy Johnson Bar No. 24126964 [email protected] Envelope ID: 104833744 Filing Code Description: Motion Filing Description: 2025 0826 2nd MET Status as of 8/26/2025 7:41 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason M.Davis [email protected] 8/26/2025 7:32:45 AM SENT Ted Ross 24008890 [email protected] 8/26/2025 7:32:45 AM SENT Jeff Lutz [email protected] 8/26/2025 7:32:45 AM SENT Hayley Ellison [email protected] 8/26/2025 7:32:45 AM SENT Katherine Johnson 24126964 [email protected] 8/26/2025 7:32:45 AM SENT