Whittney Ford v. the University of Texas at Austin

ACCEPTED
15-25-00123-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
8/26/2025 12:54 PM
No. 15-25-00123-CV CHRISTOPHER A. PRINE
______________________________ CLERK
FILED IN
15th COURT OF APPEALS
IN THE COURT OF APPEALS AUSTIN, TEXAS
FOR THE FIFTEENTH JUDICIAL DISTRICT
8/26/2025 12:54:39 PM
______________________________CHRISTOPHER A. PRINE
Clerk

WHITTNEY FORD,
Plaintiff/Appellant,

v.

JIM DAVIS AND THE UNIVERSITY OFTEXAS AT AUSTIN,
Defendants/Appellees

On Appeal from Cause No. D-1-GN-24-002171, in the
261st District Court of Travis County, Texas
______________________________

APPELLEES JIM DAVIS AND THE UNIVERSITY OF TEXAS AT
AUSTIN’S UNOPPOSED MOTION TO EXTEND TIME TO FILE
APPELLEES’ BRIEF
______________________________

TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

Appellees, Jim Davis, in his official capacity as President of The University of

Texas at Austin, and the University of Texas at Austin, pursuant to Tex. R. App. P.

38.6(d), file this Unopposed Motion to Extend Time to File Appellees’ Brief and

would respectfully shows as follows:

1. The deadline for Appellees’ Brief is set for September 15, 2025.

2. Appellees’ counsel requests a 30-day extension to this deadline, until

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October 15 2025, to file Appellees’ Brief.

3. Among other matters, Appellees’ counsel Rachel Behrendt is

representing the Texas Comptroller in an upcoming weeklong jury trial in

September, in Arnulfo P. Alcorta, et al. v. Glenn Allen Hegar, Jr., Texas Comptroller of

Public Accounts, Cause No. D-1-GN-17-006831 in the 200th Judicial District, Travis

County, TX; and presently has a deadline for a Motion for Summary Judgment and

response to a Motion for Summary Judgment due in October in Alan Scott Caver v.

Attorney General of Texas, Cause No. CIV23-0603 in the 411th District Court of Polk

County, TX, which she will need to submit earlier due to an upcoming medical

procedure that she will be taking a substantial amount of leave for. Likewise,

Appellee’s counsel Zachary Rhines has a full caseload, with likewise has a full

caseload, with his work on League of United Latin American Citizens, et al., v. Greg

Abbott, in his official capacity as Governor of the State of Texas, et al., Case No. 3:21-

CV-00259-DCG-JES-JVB in the United States District Court for the Western

District of Texas as well as an appellate brief due on September 22, 2025.

4. The undersigned respectfully requests additional time to review

Whittney Ford’s Appellant’s Brief and adequately brief the relevant issues.

5. This is Appellees’ first request for an extension in this case. This

request is sought not for the purposes of delay, but so that justice may be done.

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6. On August 26, 2025, the undersigned conferred with Appellant, who is

unopposed to the requested extension.

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

KIMBERLY GDULA
Division Chief, General Litigation Division

/s/ Rachel L. Behrendt
RACHEL L. BEHRENDT
Texas Bar No. 24130871
Assistant Attorney General

ZACHARY L. RHINES
Texas Bar No. 24116957
Special Counsel

P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Telephone: (737) 231-8329
Facsimile: (512) 320-0667
Rachel.Behrendt@oag.texas.gov
Zachary.Rhines@oag.texas.gov

ATTORNEYS FOR APPELLEES

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CERTIFICATE OF CONFERENCE

On August 26, 2025, counsel for Appellees conferred with Appellant
Whittney Ford, regarding the foregoing motion. Mr. Ford informed the undersigned
that he is not opposed to this motion.

/s/ Rachel L. Behrendt
RACHEL L. BEHRENDT
Assistant Attorney General

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing instrument has
been served on August 26, 2025, on the following parties by e-service:

Martin Cohick
State Bar No. 24134042
Assistant Attorney General
Administrative Law Division
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Telephone: (512) 936-1317
Facsimile: (512) 320-0167
martin.cohick@oag.texas.gov

Counsel for Texas Attorney General Ken Paxton

Whittney Ford
4151 Wellborn Road
Apartment 1101A
Bryan, Texas 77801
Tel: (979) 264-4944
wjacksonford@gmail.com

Plaintiff Pro Se

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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.

Ariana Ines on behalf of Rachel Behrendt
Bar No. 24130871
ariana.ines@oag.texas.gov
Envelope ID: 104858422
Filing Code Description: Motion
Filing Description: APPELLEES JIM DAVIS AND THE UNIVERSITY OF
TEXAS AT AUSTINS UNOPPOSED MOTION TO EXTEND TIME TO
FILE APPELLEES BRIEF
Status as of 8/26/2025 1:36 PM CST

Associated Case Party: The University of Texas at Austin

Name BarNumber Email TimestampSubmitted Status

Zachary Rhines 24116957 zachary.rhines@oag.texas.gov 8/26/2025 12:54:39 PM SENT

Martin Cohick 24134042 martin.cohick@oag.texas.gov 8/26/2025 12:54:39 PM SENT

Rachel Behrendt 24130871 rachel.behrendt@oag.texas.gov 8/26/2025 12:54:39 PM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Wolfgang P.Hirczy de Mino wphdmphd@gmail.com 8/26/2025 12:54:39 PM SENT

Ariana Ines ariana.ines@oag.texas.gov 8/26/2025 12:54:39 PM SENT

Associated Case Party: Whittney Ford

Name BarNumber Email TimestampSubmitted Status

Whitney Ford wjacksonford@gmail.com 8/26/2025 12:54:39 PM SENT