Jorge R. Guevara, M.D. v. Texas Medical Board

ACCEPTED
15-25-00036-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
8/26/2025 7:32 AM
CHRISTOPHER A. PRINE
CASE NO. 15-25-00036-CV CLERK
__________________________________________________________________
FILED IN
15th COURT OF APPEALS
AUSTIN, TEXAS
IN THE COURT OF APPEALS 8/26/2025 7:32:45 AM
FOR THE FIFTEENTH DISTRICT OF TEXAS AT AUSTIN A. PRINE
CHRISTOPHER
__________________________________________________________________
Clerk

JORGE R. GUEVARA, M.D.,
Appellant,

v.

TEXAS MEDICAL BOARD
Appellee.
__________________________________________________________________

APPELLEE TEXAS MEDICAL BOARD’S SECOND UNOPPOSED
MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S
BRIEF
__________________________________________________________________

TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

In accordance with Texas Rules of Appellate Procedure 10.5(b) and

38.6(d), Appellee the Texas Medical Board (TMB) respectfully requests a

30-day extension of time to file its brief. In support of the motion,

Appellee TMB would show the following:

1. The deadline for filing Appellee’s brief is August 29, 2025.

2nd Unopposed Motion for Extension of Time
Page 1 of 5
2. Appellee TMB requests a 30-day extension from the current

deadline to file its brief. If granted, this extension would cause Appellee’s

brief to be due on September 29, 2025.

3. Counsel for TMB requires an extension due to multiple

competing deadlines. Between counsel’s first and second request for an

extension of time, counsel has been preparing for her first oral argument

before the Texas Supreme Court, submitted a petition for review to the

Texas Supreme Court, provided general counsel services at three board

meetings, drafted an appellate brief in Omietimi v. Texas Board of

Nursing, Case No. 15-25-00033-CV, before the 15th Court of Appeals, and

prepared for a hearing on the merits scheduled for August 27, 2025 before

the 250th Judicial District of Travis County. She will need 30 more days

to finish the brief in the above-captioned case.

4. Counsel for Appellant Dr. Guevara does not oppose the

requested extension.

5. One previous motion for extension of time to file Appellee’s

brief has been granted.

2nd Unopposed Motion for Extension of Time
Page 2 of 5
WHEREFORE, PREMISES CONSIDERED, Appellee TMB

respectfully requests that this honorable Court grant its motion for

extension of time.

Respectfully submitted,

KEN PAXTON
Attorney General of Texas

BRENT WEBSTER
First Assistant Attorney General

RALPH MOLINA
Deputy First Assistant Attorney
General

AUSTIN KINGHORN
Deputy Attorney General for Civil
Litigation

ERNEST C. GARCIA
Chief, Administrative Law Division

/s/Kathy Johnson
KATHY JOHNSON
Assistant Attorney General
Texas State Bar No. 24126964
Ted A. Ross
Assistant Attorney General
State Bar No. 24008890
Office of the Attorney General
Administrative Law Division
P.O. Box 12548, Capitol Station

2nd Unopposed Motion for Extension of Time
Page 3 of 5
Austin, Texas 78711-2548
Telephone: (512) 475-4164
kathy.johnson@oag.texas.gov

ATTORNEYS FOR APPELLEE
TEXAS MEDICAL BOARD

CERTIFICATE OF CONFERENCE

I hereby certify that I have conferred with Hayley Ellison, counsel

for Appellant Dr. Guevara, by email on August 25, 2025. Appellant does

not oppose the granting of the relief requested in this motion.

/s/Kathy Johnson
KATHY JOHNSON
ASSISTANT ATTORNEY GENERAL

2nd Unopposed Motion for Extension of Time
Page 4 of 5
CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoing motion was

served on the following counsel of record for Appellant by electronic

service and/or e-mail on August 26, 2025:

Hayley Ellison
Davis & Santos, PLLC
719 S. Flores St.
San Antonio, TX 78204
P: 210-853-5882
hellison@dslawpc.com

ATTORNEY FOR APPELLANT

/s/Kathy Johnson
KATHY JOHNSON
ASSISTANT ATTORNEY GENERAL

2nd Unopposed Motion for Extension of Time
Page 5 of 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
certificate of service that complies with all applicable rules.

Jeff Lutz on behalf of Kathy Johnson
Bar No. 24126964
jeff.lutz@oag.texas.gov
Envelope ID: 104833744
Filing Code Description: Motion
Filing Description: 2025 0826 2nd MET
Status as of 8/26/2025 7:41 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Jason M.Davis jdavis@dslawpc.com 8/26/2025 7:32:45 AM SENT

Ted Ross 24008890 Ted.Ross@oag.texas.gov 8/26/2025 7:32:45 AM SENT

Jeff Lutz jeff.lutz@oag.texas.gov 8/26/2025 7:32:45 AM SENT

Hayley Ellison Hellison@dslawpc.com 8/26/2025 7:32:45 AM SENT

Katherine Johnson 24126964 kathy.johnson@oag.texas.gov 8/26/2025 7:32:45 AM SENT