Texas Health and Human Services Commission; Cecile Erwin Young, Executive Commissioner; Laura Castillo, Director of Heightened Monitoring; And Department of Family and Protective Services v. Kenneth Collier, Taneshu Collier, TRELS Home for Children, and TRELS Home LLC

ACCEPTED
15-25-00182-cv
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
11/20/2025 10:33 AM
No. 15-25-00182-CV CHRISTOPHER A. PRINE
CLERK
FILED IN
In the Court of Appeals 15th COURT OF APPEALS
AUSTIN, TEXAS
for the Fifteenth Judicial District 11/20/2025 10:33:43 AM
Austin, Texas CHRISTOPHER A. PRINE
Clerk

Texas Health and Human Services Commission, Et Al.,
Appellants,
V.

Kenneth Collier, Taneshu Collier, TRELS Home for Children, and TRELS
Home LLC
Appellees.

On Appeal from the 345th Judicial District Court, Travis County, Texas
Cause Number D-1-GN-25-004379

Appellants’ Opposed First Motion for Extension of Time
to File Appellants’ Brief

KEN PAXTON KIMBERLY GDULA
Attorney General of Texas Chief for General Litigation Division

BRENT WEBSTER KELSEY HANSON
First Assistant Attorney General Assistant Attorney General
Texas Bar No. 24096654
RALPH MOLINA
Deputy First Assistant Attorney Office of the Attorney General
General General Litigation Division
P.O. Box 12548, Capitol Station
AUSTIN KINGHORN Austin, Texas 78711-2548
Deputy Attorney General for Civil (737) 224-1244| FAX: (512) 320-0667
Litigation Kelsey.hanson@oag.texas.gov
MOTION TO EXTEND

1. Appellants ask the Court to grant an extension of fourteen (14) days to file

their brief, extending the due date from December 2, 2025, to December 16, 2025.

2. This is Appellants’ first request for an extension of time to file their brief.

3. Good cause exists for the Court to grant this extension.

4. The undersigned counsel, Kelsey Hanson, (1) must prepare for and attend a

hearing setting on another client’s Plea to the Jurisdiction and Motion to Stay

Discovery in Cause No. D-1-GN-24-003265 in Travis County District Court on

November 25, 2025; and (2) the undersigned counsel’s office is closed on

November 27, 2025, and November 28, 2025, for the Thanksgiving holiday.

5. Additionally, Appellants’ client representatives who will need to review and

approve of the Appellants’ brief prior to filing also have office closures for their

respective agencies the week of November 24, 2025, as well as personal

commitments related to the Thanksgiving holiday the week of November 24, 2025.

6. Due to these reasons and other time constraints, Appellants require

additional time to submit their Appellants’ Brief.

7. This extension is not being sought for purposes of delay but so that justice

may be done.

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8. The undersigned counsel conferred with counsel for Appellees, Ms. Kyle

Ferguson, via email on November 20, 2025, and Ms. Kyle Ferguson indicated that

Appellees are opposed to Appellants’ request for a 14-day extension of the due date

for Appellants’ Brief.

9. All facts recited in this motion are within the personal knowledge of the

undersigned counsel, so no verification is necessary under Texas Rule of Appellate

Procedure 10.2.

PRAYER

Appellants request that this motion be granted, extending the time for filing

Appellants’ Brief to December 16, 2025.

KEN PAXTON KIMBERLY GDULA
Attorney General of Texas Chief for General Litigation Division

BRENT WEBSTER KELSEY HANSON
First Assistant Attorney General Assistant Attorney General
Texas Bar No. 24096654
RALPH MOLINA
Deputy First Assistant Attorney Office of the Attorney General
General General Litigation Division
P.O. Box 12548, Capitol Station
AUSTIN KINGHORN Austin, Texas 78711-2548
Deputy Attorney General for Civil (737) 224-1244| FAX: (512) 320-0667
Litigation Kelsey.hanson@oag.texas.gov

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CERTIFICATE OF CONFERENCE

Kelsey Hanson conferred with Ms. Kyle Ferguson, counsel for Appellees, by
email on November 20, 2025. Appellees are opposed to this motion.

/s/ Kelsey Hanson
KELSEY HANSON
Assistant Attorney General

CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing was filed electronically
and that notice of this filing will be sent to the following persons through File & Serve
Texas’s electronic filing system on November 20, 2025:

Kyle Ferguson
John Ferguson
Meghan Rudnai
Ferguson Law Practice, PLLC
1017 RR 620 S., Suite 222
Lakeway, TX 78734
Telephone: (512) 996-5407
Attorneys For Appellees

/s/ Kelsey Hanson
Kelsey Hanson
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.

Kelsey Hanson on behalf of Kelsey Hanson
Bar No. 24096654
kelsey.hanson@oag.texas.gov
Envelope ID: 108274534
Filing Code Description: Motion
Filing Description: 20251120 Appellants First MTE to file Brief
Status as of 11/20/2025 10:43 AM CST

Associated Case Party: TEXAS HEALTH AND HUMAN SERVICES COMMISSION

Name BarNumber Email TimestampSubmitted Status

Chelsea Goodman chelsea.goodman@oag.texas.gov 11/20/2025 10:33:43 AM SENT

Kelsey Hanson kelsey.hanson@oag.texas.gov 11/20/2025 10:33:43 AM SENT

Associated Case Party: KENNETH COLLIER

Name BarNumber Email TimestampSubmitted Status

Kyle Ferguson kyle@fergusonlawpractice.com 11/20/2025 10:33:43 AM SENT

John Ferguson john@fergusonlawpractice.com 11/20/2025 10:33:43 AM SENT

Meghan Rudnai meghan@fergusonlawpractice.com 11/20/2025 10:33:43 AM SENT