NO. 03-14-00644-CV

_____________________________________________________________ 

IN THE COURT OF APPEALS 

THIRD DISTRICT OF TEXAS 

AUSTIN, TEXAS 

_____________________________________________________________ 

JOSE A. PEREZ, 

 Appellant, 

v.

TEXAS MEDICAL BOARD, et al., 

 Appellees. 

_____________________________________________________________ 

APPELLEES’ UNOPPOSED MOTION 

FOR EXTENSION OF BRIEFING DEADLINE 

_____________________________________________________________

TO THE HONORABLE JUSTICES OF THE THIRD COURT OF APPEALS: 

 Appellees, the Texas Medical Board, and Mari Robinson, JD, in her Official 

Capacity; respectfully move this Court for an extension of the deadline for filing 

their brief in response to Appellant’s amended brief in the captioned appeal. In 

support, Appellees would show the Court as follows: 

1. Appellees’ response to Appellant’s amended brief is currently due on 

March 30, 2015. No previous extensions have been requested or granted. 

2. Appellees request an extension of time to April 7, 2015 in which to 

file their responsive brief. 

ACCEPTED

03-14-00644-CV

4676007

THIRD COURT OF APPEALS

AUSTIN, TEXAS

3/27/2015 2:43:25 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 3/27/2015 2:43:25 PM JEFFREY D. KYLE Clerk
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3. The undersigned counsel for Appellees had several conflicts during 

the weeks of March 16 and 23, including emergency hearings and other matters. 

In addition, the Office of the Attorney General is closed on Friday, April 3.

4. This Motion is not interposed for the purpose of delay, but only for 

the purpose of allowing counsel to adequately prepare and file Appellees’ 

responsive brief and fully address the issues raised therein.

5. Appellant pro se has advised that he does not oppose the requested 

extension.

Appellees therefore respectfully request an extension of time to, and 

including, April 7, 2015, in which to file and serve their brief in the captioned 

appeal.

Dated: March 27, 2015.

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
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/s/ Ted A. Ross

Ted A. Ross

Assistant Attorney General

State Bar No. 24008890

OFFICE OF THE TEXAS ATTORNEY GENERAL

ADMINISTRATIVE LAW DIVISION

P. O. Box 12548

Austin, Texas 78711-2548

Telephone: (512) 475-4191

Facsimile: (512) 457-4674

Email: ted.ross@texasattorneygeneral.gov

Attorneys for Appellees the Texas Medical Board 

and Mari Robinson, JD, in her Official Capacity

CERTIFICATE OF CONFERENCE

I hereby certify that I contacted Appellant pro se and that he stated that he 

does not oppose this motion.

/s/ Ted A. Ross

Ted A. Ross 

Assistant Attorney General

CERTIFICATE OF SERVICE

I hereby certify that, in compliance with Rule 9.5 of the Texas Rules of 

Appellate Procedure, a true and correct copy of the above and foregoing document 

has been served on the following on this the 27th day of March 2015:

Jose A. Perez, pro se Via: Electronic Mail and 

34 Candle Pine Place CMRRR #7012 1010 0002 4081 4946

The Woodlands, Texas 77381

Email: theaesculapius@gmail.com

/s/ Ted A. Ross

Ted A. Ross 

Assistant Attorney Genera