ACCEPTED 15-25-00216-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 12/11/2025 2:02 PM CASE NO. 15-25-00216-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 12/11/2025 2:02:10 PM __________________________________________________________________ CHRISTOPHER A. PRINE Clerk MARY BETH BURTON, Appellant, v. TEXAS HEALTH AND HUMAN SERVICES COMMISSION, Appellee. __________________________________________________________________ APPELLEE TEXAS HEALTH AND HUMAN SERVICES COMMISSION’S FIRST 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 Health and Human Services Commission (HHSC) respectfully requests a 60-day extension of time to file its Appellee brief. In support of the motion, Appellee HHSC would show the following: 1. The deadline for filing Appellee’s brief is December 10, 2025.

Motion for Extension of Time Page 1 of 4 2. Appellee HHSC requests a 60-day extension from the current deadline to file Appellee’s brief. If granted, this extension would cause Appellee’s brief to be due on February 9, 2026.

3. Counsel for Appellee HHSC requests an extension due to the particular procedural history in this case and the upcoming holiday break. In this case, Appellant filed her brief(s) before the filing of the reporter’s record, shortening the typical appellate briefing timeline. See Tex. R. App. Pro. 38.6. Additionally, Appellee’s attorney will be out of the office from December 22, 2025—January 9, 2026, due to the holidays.

Therefore, Appellee requests an extension to file its brief. Appellee’s counsel attempted to confer with Appellant on December 10, 2025, but has not yet heard back from Appellant. It is unknown whether or not Appellant opposes the requested extension of time.

4. No previous motions for extension of time to file Appellee’s brief have been filed.

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

Motion for Extension of Time Page 2 of 4 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 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 HEALTH AND HUMAN SERVICES

Motion for Extension of Time Page 3 of 4 CERTIFICATE OF CONFERENCE I hereby certify that I attempted to confer with Appellant Mary Beth Burton, Pro Se, by email on December 10, 2025.

/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 Appellant by electronic service and/or e-mail on December 11, 2025:

Mary Beth Burton [email protected] APPELLANT PRO SE

/s/Kathy Johnson KATHY JOHNSON ASSISTANT ATTORNEY GENERAL 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: 108996317 Filing Code Description: Motion Filing Description: Appellee's 1st MET re Brief Status as of 12/11/2025 2:19 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Mary BethBurton [email protected] 12/11/2025 2:02:10 PM SENT Kathy Johnson [email protected] 12/11/2025 2:02:10 PM SENT Christian Young [email protected] 12/11/2025 2:02:10 PM SENT