NO. 01-15-00321-CV

____________________________________________________ 

IN THE FIRST COURT OF APPEALS 

AT HOUSTON, TEXAS 

____________________________________________________ 

TEXAS DEPARTMENT OF INSURANCE, DIVISION OF WORKERS’ 

COMPENSATION, 

 Appellant, 

v.

LINDA GREEN, 

 Appellee. 

____________________________________________________ 

On Appeal from the 133rd District Court, Harris County, Texas 

____________________________________________________ 

APPELLANT’S UNOPPOSED MOTION 

FOR EXTENSION OF TIME TO FILE REPLY BRIEF 

TO THE HONORABLE FIRST COURT OF APPEALS: 

COMES NOW, Appellant, Texas Department of Insurance, Division of 

Workers’ Compensation, and files this Unopposed Motion for Extension of Time to 

File Reply Brief in the above captioned appeal, and in support thereof will show the 

following: 

I.

This case is on appeal from the 133rd District Court of Harris County, Texas, 

of an Order denying Appellant’s Plea to the Jurisdiction on March 2, 2015. 

ACCEPTED

01-15-00321-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

7/10/2015 1:36:20 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 7/10/2015 1:36:20 PM CHRISTOPHER A. PRINE Clerk
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II.

This case was instituted in the Court of Appeals on April 9, 2015. The clerk’s 

record was filed on April 16, 2015. There was no court reporter’s record. 

III.

Appellant’s brief was filed on May 14, 2015. Appellee’s Brief was filed on 

July 3, 2015. Appellant’s Reply Brief was due on July 6, 2015.

IV.

Appellant requests an extension until today to file its Reply Brief. This is an 

accelerated appeal. The deadline for Appellant to file its Reply Brief was three days 

after Appellee file her brief. The deadline date of July 6 was part of a holiday 

weekend, and due to time constraints, counsel for Appellant needed additional time 

to read, analyze and reply to Appellee’s Brief. Thus, Appellant asks for an 

extension of today to file its reply.

V.

The undersigned corresponded with counsel for Appellee on July 10, 2015, 

and this motion is unopposed by Appellee.

WHEREFORE PREMISES CONSIDERED, Appellant, Texas Department of 

Insurance-Division of Workers’ Compensation respectfully requests that the First

Court of Appeals grant an extension of time until July 10, 2015 in which to file its 

reply brief on appeal.
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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.

Division Chief, Administrative Law Division

 /s/ Dennis M. McKinney 

DENNIS M. MCKINNEY

State Bar No.13719300

Assistant Attorney General

Administrative Law Division

OFFICE OF THE ATTORNEY GENERAL OF 

TEXAS 

P.O. Box 12548, Capitol Station

Austin, Texas 78711-2548

Telephone: (512) 475-4020

Facsimile: (512) 320-0167

Dennis.McKinney@texasattorneygeneral.gov

Attorneys for Appellant

CERTIFICATE OF CONFERENCE

I hereby certify that I have conferred with counsel for Appellee and he is 

unopposed to this request for extension.

 /s/ Dennis M. McKinney 

DENNIS M. MCKINNEY

Assistant Attorney General
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CERTIFICATE OF SERVICE

I hereby certify that on July 10, 2015, a true and correct copy of the above and 

forgoing document was sent by e-service or electronic mail to the following parties:

Brad McClellan Via E-Service and/or E-Mail

LAW OFFICES OF RICHARD PENA, P.C.

1701 Directors Blvd, Suite 110

Austin, Texas 78744

brad.mcclellan@yahoo.com

Attorney for Appellee

David Brenner Via E-Service and/or E-Mail

Belinda May Arambula

BURNS ANDERSON JURY & BRENNER, L.L.P.

P.O. Box 26300

Austin, Texas 78755-6300

7804 Bell Mountain Drive, # 100

Austin, Texas 78730

dbrenner@bajb.com

barambula@bajb.com

Attorneys for Defendant Zurich American

Raymond L. Kalmans Via E-Service and/or E-Mail

Stephen L. Brochstein

Schlanger, Silver, Barg & Paine, LLP

109 North Post Oak Lane, Ste. 300

Houston, Texas 77024

rkalmans@ssbplaw.com

Attorneys for Intervenor Bessie A. Wilhelm

 /s/ Dennis M. McKinney 

DENNIS M. MCKINNEY

Assistant Attorney General