NO. 04-15-00473-CV

IN THE FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

_______________________________________

TEXAS DEPARTMENT OF INSURANCE - DIVISION OF WORKERS’ 

COMPENSATION and COMMISSIONER RYAN BRANNAN, IN HIS 

OFFICIAL CAPACITY, 

Appellants, 

v.

DALE BRUMFIELD, 

Appellee. 

_______________________________________

On Appeal from the 288th Judicial District Court, Cause No. 2015CI07374

_______________________________________

APPELLANTS TEXAS DEPARTMENT OF INSURANCE - DIVISION OF 

WORKERS’ COMPENSATION AND COMMISSIONER BRANNAN’S 

UNOPPOSED MOTION TO EXTEND TIME TO FILE REPLY BRIEF 

_______________________________________

TO THE HONORABLE JUSTICES OF THE FOURTH COURT OF APPEALS:

Appellants the Texas Department of Insurance - Division of Workers’ 

Compensation and Commissioner Ryan Brannan respectfully move this Court for an 

extension of the deadline for filing their reply brief. In support, Appellants show 

the Court as follows:

ACCEPTED

04-15-00473-CV

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

12/3/2015 3:53:01 PM

KEITH HOTTLE

CLERK

 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 12/3/2015 3:53:01 PM KEITH E. HOTTLE Clerk
1. Appellants’ reply brief is currently due on December 9, 2015. 

Appellants request a thirty day extension of their briefing deadline.

2. Appellants request an extension of time based on Appellants’ counsel’s 

current caseload and holiday schedule. Appellants also request the 

extension based upon the need to fully address the complex issues and 

briefing of this case.

3. Appellants move for this extension not to delay proceedings but to

allow their counsel sufficient time to adequately prepare and file a reply 

brief that fully addresses the issues raised by Mr. Brumfield in his 

response.

4. Appellants’ counsel conferred with counsel for Appellee about this 

motion. The requested extension is not opposed.

Accordingly, Appellants respectfully request an extension of time up to and 

including Friday, January 8, 2016 to file and serve their reply brief.

Dated: December 3, 2015.

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Respectfully submitted,

KEN PAXTON

Attorney General of Texas

CHARLES E. ROY

First Assistant Attorney General

JAMES E. DAVIS

Deputy Attorney General for Civil Litigation

DAVID A. TALBOT, JR. 

Chief, Administrative Law Division

/s/ Harold J. Liller 

HAROLD J. LILLER

State Bar No. 24029689

Assistant Attorney General

Administrative Law Division

OFFICE OF THE TEXAS ATTORNEY GENERAL

P.O. Box 12548, Capitol Station

Austin, Texas 78711-2548

Telephone: (512) 475-4300

Facsimile: (512) 320-0167

harold.liller@texasattorneygeneral.gov

Counsel for Appellees Texas Department of 

Insurance - Division of Workers' 

Compensation and Commissioner Ryan 

Brannan

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CERTIFICATE OF CONFERENCE

On December 3, 2015 counsel for Appellants conferred with counsel for 

Appellee about the contents of this motion, and Appellee’s counsel stated he is 

unopposed to the requested extension.

/s/ Harold J. Liller 

HAROLD J. LILLER

Assistant Attorney General

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and forgoing 

document has been served by facsimile on this date, the 3rd day of December, 2015, 

on the following:

Bradley Dean McClellan

State Bar No. 13395980

Of Counsel, THE LAW OFFICES OF RICHARD PENA, P.C.

1701 Director’s Blvd., Suite 110

Austin, Texas 78744

Facsimile: (512) 327-8354

Email: Brad.McClellan@yahoo.com

Counsel for Appellee Dale Brumfield

/s/ Harold J. Liller 

HAROLD J. LILLER

Assistant Attorney General

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