Cecile Erwin Young, in Her Official Capacity as the Executive Commissioner of the Texas Health and Human Services Commission; Molina Healthcare of Texas, Inc.; And Aetna Better Health of Texas, Inc. v. Cook Children's Health Plan, Texas Children's Health Plan, Superior Health Plan, Inc., and Wellpoint Insurance Company

ACCEPTED
15-24-00114-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
8/13/2025 8:10 AM
No. 15-24-00114-CV CHRISTOPHER A. PRINE
CLERK

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

for the Fifteenth Judicial District8/13/2025 8:10:17 AM
AUSTIN, TEXAS

CHRISTOPHER A. PRINE
Clerk
Cecile Erwin Young, in her Official Capacity as the
Executive Commissioner of the Texas Health and Human
Services Commission; Molina Healthcare of Texas, Inc.;
and Aetna Better Health of Texas, Inc.
Appellants,
v.
Cook Children’s Health Plan, Texas Children’s Health
Plan, Superior Health Plan, Inc., and Wellpoint
Insurance Company,
Appellees.

On Appeal from the
353rd Judicial District Court, Travis County

UNOPPOSED MOTION FOR EXTENSION OF
TIME TO FILE APPELLANT CECILE ERWIN
YOUNG’S APPELLANT’S BRIEF

To the Honorable Fifteenth Court of Appeals:
In accordance with Texas Rule of Appellate Procedure 10.5(b), Appellant Cecile
Erwin Young, in her official capacity as the Executive Commissioner of the Texas

Health and Human Services Commission, files this motion for an extension of time
to file her Appellant’s Brief. This is the first request for an extension of time for this
filing, and it is unopposed.
I.
The current due date for the Commissioner to file her brief is August 28, 2025.
The Commissioner requests a 30-day extension of the time to file the brief, which
would extend the due date to September 29.

II.
The requested 30-day extension of time is necessary due to multiple
engagements by Appellant’s counsel that have required or will require significant

attention, including:

• oral argument in Ballentine v. Broxton, No. 24-50876, which occurred on
August 6, 2025, in the United States Court of Appeals for the Fifth Circuit;
• a petition for writs of quo warranto in In re State, No. 25-0687, filed in the Texas
Supreme Court on August 8, 2025;
• a reply in support of a petition for writ of mandamus in In re Ken Paxton, No. 25-
0641, filed in the Texas Supreme Court on August 8, 2025;
• a brief on the merits in In re State, No. 25-0687, due to be filed in the Texas
Supreme Court on August 20, 2025;
• a response to Rule 29.3 motions in this case, due to be filed in this Court on
August 25, 2025;
• an opening brief on the merits in State of Texas v. FERC, No. 24-1758, due to be
filed in the United States Court of Appeals for the Fourth Circuit on August 29,
2025;
• a reply brief on the merits in In re State, No. 25-0687, due to be filed in the Texas
Supreme Court on September 4, 2025;
• a reply brief on the merits in Paxton v. Garza, No. 15-25-00116-cv, due to be
filed in this Court on September 8, 2025;
• oral argument in Sky Marketing Corp. v. Tex. Dep’t of State Health Servs., No.
23-0887, set for September 10, in the Texas Supreme Court; and
• a multi-state amicus brief in Galette v. N.J. Transit Corp., No. 24-1021, due
September 10, in the Supreme Court of the United States.

2
In addition to briefing and argument obligations, counsel has numerous
prelitigation, oversight, and managerial responsibilities and continues to be staffed

on other public and non-public litigation and advisory matters throughout the Office
of the Attorney General.
The extension is sought in the interest of justice, not for delay, and no party will
be prejudiced if this unopposed request for an extension of time is granted, including
because no party is seeking emergency review. An extension of time will allow
counsel for the Commissioner adequate time to review the voluminous record and

prepare a thorough brief that will be helpful to the Court.

3
Prayer
For these reasons, the Commissioner respectfully requests that the Court grant
her unopposed motion for a 30-day extension of time to file her Appellant’s Brief,
resulting in a new deadline of September 29, 2025.

Respectfully submitted.

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

Brent Webster William F. Cole
First Assistant Attorney General Principal Deputy Solicitor General

Office of the Attorney General /s/ Cory A. Scanlon
P.O. Box 12548 (MC 059) Cory A. Scanlon
Austin, Texas 78711-2548 Assistant Solicitor General
Tel.: (512) 936-1700 State Bar No. 24104599
Fax: (512) 474-2697 Cory.Scanlon@oag.texas.gov

Jeffrey A. Stephens
Assistant Solicitor General

Brendan A. Fugere
Assistant Attorney General

Counsel for Appellant Cecile Erwin
Young

4
Certificate of Conference
I certify that on August 12, 2025, I conferred with counsel for all Appellees, who
informed me that they do not oppose the extension sought through this motion.
Counsel for Appellants Molina Healthcare of Texas, Inc. and Aetna Better Health
of Texas, Inc., stated that they take no position on this motion but have indicated a
preference that the briefing schedules be aligned for all appellants.

/s/ Cory A. Scanlon
Cory A. Scanlon

5
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
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Nancy Villarreal on behalf of Cory Scanlon
Bar No. 24104599
nancy.villarreal@oag.texas.gov
Envelope ID: 104302705
Filing Code Description: Motion
Filing Description: 20250813 MET Appellants Brief_Final
Status as of 8/13/2025 8:24 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Michaelle Peters mpeters@scottdoug.com 8/13/2025 8:10:17 AM SENT

Julie Wright julie.wright@nortonrosefulbright.com 8/13/2025 8:10:17 AM SENT

Amanda DoddsPrice amanda.price@squirepb.com 8/13/2025 8:10:17 AM SENT

Mandy Patterson mpatterson@adjtlaw.com 8/13/2025 8:10:17 AM SENT

Michelle Joyner mjoyner@scottdoug.com 8/13/2025 8:10:17 AM SENT

William FCole William.Cole@oag.texas.gov 8/13/2025 8:10:17 AM SENT

Abril Rivera arivera@scottdoug.com 8/13/2025 8:10:17 AM SENT

Nancy Villarreal nancy.villarreal@oag.texas.gov 8/13/2025 8:10:17 AM SENT

Jessie Johnson jessie.johnson@nortonrosefulbright.com 8/13/2025 8:10:17 AM SENT

David Johns david@cobbjohns.com 8/13/2025 8:10:17 AM SENT

Stacey Jett sjett@adjltaw.com 8/13/2025 8:10:17 AM SENT

Associated Case Party: Cook Children's Health Plan

Name BarNumber Email TimestampSubmitted Status

Karen Burgess 796276 kburgess@burgesslawpc.com 8/13/2025 8:10:17 AM SENT

Anna Baker 791362 abaker@adjtlaw.com 8/13/2025 8:10:17 AM SENT

Amy Warr 795708 awarr@adjtlaw.com 8/13/2025 8:10:17 AM SENT

Juliana Bennington jbennington@perkinscoie.com 8/13/2025 8:10:17 AM SENT

Jonathan Hawley jhawley@perkinscoie.com 8/13/2025 8:10:17 AM ERROR

Reina A.Almon-Griffin ralmon-Griffin@perkinscoie.com 8/13/2025 8:10:17 AM SENT

Trisha Marino tmarino@perkinscoie.com 8/13/2025 8:10:17 AM SENT

Katie Dolan-Galaviz kgalaviz@burgesslawpc.com 8/13/2025 8:10:17 AM SENT
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 Cory Scanlon
Bar No. 24104599
nancy.villarreal@oag.texas.gov
Envelope ID: 104302705
Filing Code Description: Motion
Filing Description: 20250813 MET Appellants Brief_Final
Status as of 8/13/2025 8:24 AM CST

Associated Case Party: Cook Children's Health Plan

Katie Dolan-Galaviz kgalaviz@burgesslawpc.com 8/13/2025 8:10:17 AM SENT

Perkins Docketing Team DocketSEA@perkinscoie.com 8/13/2025 8:10:17 AM SENT

Matthew Gordon mgordon@perkinscoie.com 8/13/2025 8:10:17 AM SENT

Associated Case Party: Texas Children's Health Plan

Name BarNumber Email TimestampSubmitted Status

Mark Emery 24050564 mark.emery@nortonrosefulbright.com 8/13/2025 8:10:17 AM SENT

Warren Huang 796788 warren.huang@nortonrosefulbright.com 8/13/2025 8:10:17 AM SENT

Paul Trahan 24003075 paul.trahan@nortonrosefulbright.com 8/13/2025 8:10:17 AM SENT

Susan Harris 6876980 susan.harris@nortonrosefulbright.com 8/13/2025 8:10:17 AM SENT

Kayla Ahmed kayla.ahmed@nortonrosefulbright.com 8/13/2025 8:10:17 AM SENT

Thomas Coulter 4885500 tom.coulter@nortonrosefulbright.com 8/13/2025 8:10:17 AM SENT

Associated Case Party: Wellpoint Insurance Company

Name BarNumber Email TimestampSubmitted Status

Robert Johnson 10786400 rjohnson@foley.com 8/13/2025 8:10:17 AM SENT

Michelle Ku 24071452 mku@foley.com 8/13/2025 8:10:17 AM SENT

Benjamin Grossman bjgrossman@foley.com 8/13/2025 8:10:17 AM SENT

Kristin Hernandez kristin.hernandez@foley.com 8/13/2025 8:10:17 AM SENT

Stacey Obenhaus sobenhaus@foley.com 8/13/2025 8:10:17 AM SENT

Associated Case Party: Superior Healthplan Inc.
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 Cory Scanlon
Bar No. 24104599
nancy.villarreal@oag.texas.gov
Envelope ID: 104302705
Filing Code Description: Motion
Filing Description: 20250813 MET Appellants Brief_Final
Status as of 8/13/2025 8:24 AM CST

Associated Case Party: Superior Healthplan Inc.

Name BarNumber Email TimestampSubmitted Status

Richard Phillips 24032833 Rich.Phillips@hklaw.com 8/13/2025 8:10:17 AM SENT

J McCaig 24070083 meghan.mccaig@outlook.com 8/13/2025 8:10:17 AM SENT

Karen Walker karen.walker@hklaw.com 8/13/2025 8:10:17 AM SENT

Tiffany Roddenberry tiffany.roddenberry@hklaw.com 8/13/2025 8:10:17 AM SENT

Associated Case Party: Texas Health and Human Services

Name BarNumber Email TimestampSubmitted Status

Victoria Gomez victoria.gomez@oag.texas.gov 8/13/2025 8:10:17 AM SENT

Jennifer Cook Jennifer.Cook@oag.texas.gov 8/13/2025 8:10:17 AM SENT

Associated Case Party: Molina Healthcare of Texas, Inc.

Name BarNumber Email TimestampSubmitted Status

Cheryl LaFond 24104015 clafond@scottdoug.com 8/13/2025 8:10:17 AM SENT

Jason R.LaFond jlafond@scottdoug.com 8/13/2025 8:10:17 AM SENT

Associated Case Party: Aetna Better Health of Texas, Inc.

Name BarNumber Email TimestampSubmitted Status

Joseph Knight 11601275 jknight@ebbklaw.com 8/13/2025 8:10:17 AM SENT

Associated Case Party: Cecile Erwin Young, Texas Health and Human Services
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 Cory Scanlon
Bar No. 24104599
nancy.villarreal@oag.texas.gov
Envelope ID: 104302705
Filing Code Description: Motion
Filing Description: 20250813 MET Appellants Brief_Final
Status as of 8/13/2025 8:24 AM CST

Associated Case Party: Cecile Erwin Young, Texas Health and Human Services

Name BarNumber Email TimestampSubmitted Status

Cory Scanlon 24104599 cory.scanlon@oag.texas.gov 8/13/2025 8:10:17 AM SENT