Texas Health and Human Services Commission v. Amy Bazan A/K/A Amy Fairbank

ACCEPTED
15-25-00130-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
11/21/2025 2:36 PM
CHRISTOPHER A. PRINE
Cause No. 15-25-00130-CV CLERK
_______________________________________________________
FILED IN
15th COURT OF APPEALS
AUSTIN, TEXAS
FIFTEENTH COURT OF APPEALS 11/21/2025 2:36:11 PM
_______________________________________________________
CHRISTOPHER A. PRINE
Clerk

TEXAS HEALTH AND HUMAN SERVICES COMMISSION,
Appellant,

v.

AMY BAZAN a/k/a AMY FAIRBANK,
Appellee.
____________________________________________________

On Appeal from the 353rd Judicial District Court of Travis County, Texas
No. D-1-GN-22-000773

APPELLANT TEXAS HEALTH AND HUMAN SERVICES
COMMISSION’S UNOPPOSED MOTION FOR EXTENSION TO FILE
REPLY BRIEF
____________________________________________________

TO THE HONORABLE JUSTICES OF THE FIFTEENTH COURT OF
APPEALS:

Appellant, the Texas Health and Human Services Commission (HHSC),

respectfully requests an extension of time to and including December 29,2025 in

which to file its reply brief in the captioned appeal. In support, the HHSC would

show the Court as follows:

1. Appellant HHSC filed its Appellant Brief on October 6, 2025.

2. Appellee filed her brief on November 5, 2025.
3. Appellant HHSC’s reply brief is currently due on November 25, 2025.

4. No previous extensions have been requested or granted.

5. Counsel for Appellant HHSC is requesting the extension due to an

injury that needs considerable medical attention, as well as other unanticipated

management and work-related matters.

6. This motion is not interposed for the purpose of delay, but only to allow

Appellant HHSC’s counsel the time to adequately prepare and file a reply brief.

7. Appellee’s counsel has stated that she does not oppose this request.

Appellant HHSC therefore respectfully requests an extension of time to and

including December 29, 2025, in which to file and serve its reply brief in the

captioned appeal.

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
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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
Email: ted.ross@oag.texas.gov

Attorneys for Appellant
Texas Health & Human Services Commission

CERTIFICATE OF CONFERENCE

I hereby certify that I contacted counsel for Appellee and she stated that
Appellee does not oppose the extension requested herein.

/s/ Ted A. Ross
Ted A. Ross
Assistant Attorney General

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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 21st day of November 2025:

Prema Autry via e-Service
Texas State Bar No. 24082357
223 S. Bonner Ave.
Tyler, Texas 75702
T: (903) 705-7211
F: (903) 705-7221
pautry@laddtxlaw.com
Attorney for Appellee,
Amy Bazan a/k/a Amy Fairbank

/s/ Ted A. Ross
Ted A. Ross
Assistant Attorney General

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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 Ted Ross
Bar No. 24008890
jeff.lutz@oag.texas.gov
Envelope ID: 108345711
Filing Code Description: Motion
Filing Description: 2025 1121 Unopposed Motion for Extension reply brief
Status as of 11/21/2025 2:59 PM CST

Associated Case Party: Texas Health and Human Services Commission

Name BarNumber Email TimestampSubmitted Status

Jeff Lutz jeff.lutz@oag.texas.gov 11/21/2025 2:36:11 PM SENT

Ted Ross ted.ross@oag.texas.gov 11/21/2025 2:36:11 PM SENT

Associated Case Party: Amy Bazan

Name BarNumber Email TimestampSubmitted Status

Cheryl Kuester ckuester@laddtxlaw.com 11/21/2025 2:36:11 PM SENT

Norman Ladd nladd@laddtxlaw.com 11/21/2025 2:36:11 PM SENT

Prema Autry pautry@laddtxlaw.com 11/21/2025 2:36:11 PM SENT