Texas Department of Insurance v. Som Thomas

ACCEPTED
15-24-00073-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
12/19/2025 2:19 PM
CHRISTOPHER A. PRINE
No. 15-24-00073-CV CLERK
FILED IN
In the Court of Appeals 15th COURT OF APPEALS
AUSTIN, TEXAS

for the Fifteenth Judicial District
12/19/2025 2:19:29 PM
CHRISTOPHER A. PRINE
Clerk

Texas Department of Insurance,
Appellant,
v.
Som Thomas,
Appellee.

On Appeal from the
345th Judicial District Court, Travis county

Unopposed Motion for
Withdrawal of Counsel, and Substitution
Pursuant to Texas Rule of Appellate Procedure 6.5, Appellate Texas

Department of Insurance moves this Court to permit its lead counsel of record, Cole

P. Wilson, to withdraw from this matter. Mr. Wilson is leaving employment with the

Office of the Attorney General of Texas and will no longer be available to continue

representing Appellant in this matter. Plaintiff is unopposed to this motion.

Additionally, the undersigned asks that this Court take notice of his

appearance in this matter, and of his substitution for Mr. Wilson as lead counsel.

Because of this substitution, Appellant need not comply with Texas Rule of Appellate

Procedure 6.5(a) and (c). The undersigned’s contact information is below.
John Ramsey
Deputy Chief
General Litigation Division
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Tel: (512) 463-2120
Fax: (512) 320-0667
John.Ramsey@oag.texas.gov

For the foregoing reasons, Appellant respectfully requests that the Court

withdraw Mr. Wilson as lead counsel in this matter and remove him from the list of

counsel who receive notice of filings and case activity, and to take notice of Mr.

Ramsey’s appearance as lead counsel for Appellant.

Respectfully submitted,
KEN PAXTON
Attorney General of Texas KIMBERLY GDULA
Chief, General Litigation Division
BRENT WEBSTER
First Assistant Attorney General _____________________
JOHN RAMSEY
RALPH MOLINA Deputy Chief
Deputy First Assistant Attorney General Texas Bar No. 24051227
COLE P. WILSON
AUSTIN KINGHORN Texas Bar No. 24122856
Deputy Attorney General for Civil Assistant Attorney General
Litigation
General Litigation Division
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Tel.: (512) 463-2120
Fax: (512) 320-0667
John.Ramsey@oag.texas.gov
Counsel for Appellant
CERTIFICATE OF CONFERENCE
I hereby certify that on December 15, 2025, I conferred with counsel for the
Appellee Som Thomas (Mark Downey), who is unopposed to this motion.

/s/ Cole P. Wilson
Assistant Attorney General

CERTIFICATE OF SERVICE
I hereby certify that on December 19, 2025, I caused the foregoing to be
electronically filed with the Clerk of the Court using the eFileTexas.gov electronic
filing system, which will send notification of such filing to the email addresses
denoted on Service Contacts List.

JOHN RAMSEY
Deputy Chief
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.

Laura Hendrix on behalf of John Ramsey
Bar No. 24051227
Laura.Hendrix@oag.texas.gov
Envelope ID: 109316263
Filing Code Description: Motion
Filing Description: 20251219_Unop Mtn to Withdraw
Status as of 12/19/2025 2:54 PM CST

Associated Case Party: Texas Department of Insurance

Name BarNumber Email TimestampSubmitted Status

Rance Craft rance.craft@oag.texas.gov 12/19/2025 2:19:29 PM SENT

Philip Lionberger Philip.Lionberger@oag.texas.gov 12/19/2025 2:19:29 PM SENT

Cole Wilson Cole.Wilson@oag.texas.gov 12/19/2025 2:19:29 PM SENT

John Ramsey John.Ramsey@oag.texas.gov 12/19/2025 2:19:29 PM SENT

Laura Hendrix laura.hendrix@oag.texas.gov 12/19/2025 2:19:29 PM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Nancy Villarreal nancy.villarreal@oag.texas.gov 12/19/2025 2:19:29 PM SENT

Victor Hernandez victor.hernandez@oag.texas.gov 12/19/2025 2:19:29 PM SENT

Associated Case Party: Som Thomas

Name BarNumber Email TimestampSubmitted Status

Mark DDowney mdowney@dlawgrp.com 12/19/2025 2:19:29 PM SENT