Amparo Stiefel v. Texas Health and Human Services Commission

ACCEPTED
15-25-00176-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
12/4/2025 3:44 PM
No. 15-25-00176-CV CHRISTOPHER A. PRINE
CLERK
FILED IN
In the Fifteenth District Court of Appeals, Austin, TexasOF APPEALS
15th COURT
AUSTIN, TEXAS
12/4/2025 3:44:02 PM

AMPARO STIEFEL, CHRISTOPHER A. PRINE
Clerk
Appellant,
v.

TEXAS HEALTH AND HUMAN SERVICES COMMISSION,
Appellee.

On Appeal from the 261st District Court of Travis County, Texas
The Honorable Daniela DeSeta Lyttle, Presiding

UNOPPOSED MOTION FOR EXTENSION OF TIME FOR APPELLEE’S
BRIEF

Appellee, the Texas Health and Human Services Commission,

respectfully requests a 44-day extension of time to January 23, 2026, in

which to file its brief in the captioned appeal. Appellant is unopposed to

this motion. In support, Appellee would show the Court as follows:

1. This is Appellee’s first request for an extension.

2. This extension would make Appellee’s brief due on or before Friday,

January 23, 2026.

3. Counsel for Appellee is lead counsel for Docket No. SCR 25-0002,

In re: Hon. Amber Givens, before the Special Court of Review, which has
depositions on Friday, December 5, 2025, a 2-day trial from December

10-11, 2025, and a post-trial submission brief due on December 30, 2025.

Counsel for Appellee is also lead counsel for Docket No. 507-25-17141;

Texas Board of Nursing v. Ndirika Justina Ani, before the State Office of

Administrative Hearings, which has a hearing on the merits on January

6, 2026.

4. Additionally, the Office of the Attorney General has minimal staff

working and/or is closed from December 22, 2025, through January 2,

2026.

5. This motion is not interposed for the purpose of delay, but only to

allow Appellee’s counsel the time to adequately prepare and file its brief,

and to maintain consistent briefing schedules.

6. Counsel for Appellant is not opposed to this motion.

Appellee, the Texas Health and Human Services Commission,

therefore, respectfully requests an extension of time to and including

January 23, 2026, in which Appellee is to file and serve its brief in the

captioned appeal.

UNOPPOSED MOTION FOR EXTENSION OF TIME
Case No. 15-25-00176-CV 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/ Brad Wurster
BRADLEY WURSTER
State Bar No. 24106603
Assistant Attorney General
Administrative Law Division
Office of the Attorney General of Texas
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Telephone: (512) 475-4197
Brad.Wurster@oag.texas.gov

ATTORNEYS FOR APPELLEE TEXAS HEALTH
AND HUMAN SERVICES COMMISSION

UNOPPOSED MOTION FOR EXTENSION OF TIME
Case No. 15-25-00176-CV Page 3 of 4
CERTIFICATE OF CONFERENCE

I hereby certify that on December 4, 2025, counsel for all parties
conferred via email about the contents of this Motion and are unopposed
to the extensions being sought within the Motion.

/s/ Brad Wurster
BRAD WURSTER
Assistant Attorney General

CERTIFICATE OF SERVICE

I hereby certify that on December 4, 2025, a true and correct copy
of the above and foregoing document has been served to the following
party of record via electronic service and/or electronic mail:

DONALD M. KAISER, JR.
State Bar No. 24025466
Kaiser Legal Solutions, PLLC
5440 Harvest Hill, Suite 201
Dallas, Texas 75230
Tel.: (214) 441-3000
Fax: (214) 441-3001
Dkaiser@attorneysforbusiness.com

ATTORNEYS FOR APPELLANT
AMPARO STIEFEL

/s/ Brad Wurster
BRAD WURSTER
Assistant Attorney General

UNOPPOSED MOTION FOR EXTENSION OF TIME
Case No. 15-25-00176-CV 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.

Jennifer Foster on behalf of Brad Wurster
Bar No. 24106603
jennifer.foster@oag.texas.gov
Envelope ID: 108734328
Filing Code Description: Motion
Filing Description: Motion for Extension
Status as of 12/4/2025 3:55 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Donald M.Kaiser, Jr. dkaiser@attorneysforbusiness.com 12/4/2025 3:44:02 PM SENT

Brad Wurster Brad.Wurster@oag.texas.org 12/4/2025 3:44:02 PM SENT

Jennifer Foster Jennifer.Foster@oag.texas.gov 12/4/2025 3:44:02 PM SENT