Texas State Board of Social Worker Examiners v. Katherin Youniacutt and Tammy Thompson

ACCEPTED
15-25-00064-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
8/21/2025 3:33 PM
No. 15-25-00064-CV CHRISTOPHER A. PRINE
CLERK

In the Court of Appeals 15th COURT FILED IN
OF APPEALS

for the Fifteenth Judicial District8/21/2025 3:33:13 PM
AUSTIN, TEXAS

CHRISTOPHER A. PRINE
Clerk
Texas State Board of Social Worker Examiners, et al.,
Appellants,
v.
Katherin Youniacutt and Tammy Thompson,
Appellees.
On Appeal from the
345th Judicial District Court, Travis County

UNOPPOSED MOTION TO EXTEND TIME TO FILE
APPELLANTS’ REPLY BRIEF

Pursuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), Appellants
move to extend the time to file their reply brief by 21 days, from the current deadline
of August 27, 2025, to a proposed new deadline of September 17.

I.
Appellees filed their brief on August 7, 2025, making appellants’ reply brief due
on August 27. Tex. R. App. P. 38.6(c). Appellants now request a 21-day extension of

the time to file that brief, which would create a new deadline of September 17. This
is Appellants’ first request for an extension of their reply brief deadline.

II.
This extension is not sought for delay but to accommodate the schedule of
Appellants’ counsel, Beth Klusmann. Ms. Klusmann’s recent and upcoming

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deadlines include drafting or assisting with the follow briefs: (1) an amicus brief in
Doe v. Planned Parenthood Federation of America, No. 23-11184, currently pending

before the Fifth Circuit en banc and due September 3, 2025; and (2) a supplemental
brief in National Horsemen’s Benevolent and Protective Association v. Black, No. 23-
10520, in the Fifth Circuit, currently due September 4, 2025. In addition, Ms.
Klusmann will be assisting three colleagues prepare for oral argument in early
September.
This extension is not sought for delay, and additional time to research and

analyze the issues presented in this appeal will allow for a thorough and helpful reply
brief. Appellees do not oppose this motion.

Prayer
For the foregoing reasons, Appellants respectfully request that the Court grant
them a 21-day extension to file their reply brief, creating a new deadline of September
17.
Respectfully submitted.

Ken Paxton William R. Peterson
Attorney General of Texas Solicitor General

Brent Webster /s/ Beth Klusmann
First Assistant Attorney General Beth Klusmann
Assistant Solicitor General
Office of the Attorney General State Bar No. 24036918
P.O. Box 12548 (MC 059) Beth.Klusmann@oag.texas.gov
Austin, Texas 78711-2548
Tel.: (512) 936-1700
Fax: (512) 474-2697 Counsel for Appellants

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Certificate of Conference
I certify that on August 21, 2025, I conferred by email with James Knight, lead
counsel for Appellees, and he does not oppose this motion.
/s/ Beth Klusmann
Beth Klusmann

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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.

Nancy Villarreal on behalf of Beth Klusmann
Bar No. 24036918
nancy.villarreal@oag.texas.gov
Envelope ID: 104692215
Filing Code Description: Motion
Filing Description: 2025 0821 Youniacutt Reply MET_Final
Status as of 8/21/2025 3:41 PM CST

Associated Case Party: Katherin Youniacutt and Tammy Thompson

Name BarNumber Email TimestampSubmitted Status

Arif Panju 24070380 apanju@ij.org 8/21/2025 3:33:13 PM SENT

James T. Knight II jknight@ij.org 8/21/2025 3:33:13 PM SENT

Associated Case Party: Texas State Board of Social Workers Examiners, et al.

Name BarNumber Email TimestampSubmitted Status

John Ramsey 24051227 John.Ramsey@oag.texas.gov 8/21/2025 3:33:13 PM SENT

Beth Klusmann beth.klusmann@oag.texas.gov 8/21/2025 3:33:13 PM SENT

Ali Thorburn 24125064 ali.thorburn@oag.texas.gov 8/21/2025 3:33:13 PM SENT

Eric Abels Eric.Abels@oag.texas.gov 8/21/2025 3:33:13 PM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Nancy Villarreal nancy.villarreal@oag.texas.gov 8/21/2025 3:33:13 PM SENT

Andrew Ward andrew.ward@ij.org 8/21/2025 3:33:13 PM SENT

Ashlynn Acosta aacosta@ij.org 8/21/2025 3:33:13 PM SENT

Claire Purple cpurple@ij.org 8/21/2025 3:33:13 PM SENT