John Eric Anderson v. State of Texas

ACCEPTED
15-25-00132-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
12/9/2025 6:10 PM
No. 15-25-00132-CV CHRISTOPHER A. PRINE
CLERK
IN THE COURT OF APPEALS FILED IN
15th COURT OF APPEALS
FOR THE FIFTEENTH JUDICIAL DISTRICT OF TEXASAUSTIN, TEXAS
12/9/2025 6:10:52 PM
AUSTIN, TEXAS CHRISTOPHER A. PRINE
Clerk
J OHN E RIC ANDERSON ,
PLAINTIFF-APPELLANT,

V.

S TATE OF T EXAS, ET AL .,
DEFENDANTS-APPELLEES

ON APPEAL FROM THE 98TH JUDICIAL DISTRICT COURT
OF TRAVIS COUNTY, TEXAS; CAUSE NO. D-1-GN-001988

APPELLEES’ MOTION FOR THIRTY-DAY EXTENSION TO FILE APPELLEES’ BRIEFS
KEN PAXTON BRIANA M. WEBB
Attorney General of Texas Chief, Law Enforcement Defense
Division
BRENT WEBSTER
First Assistant Attorney General KYLE A. PERKINS*
Assistant Attorney General
AUSTIN KINGHORN
Deputy Attorney General for
Civil Litigation
OFFICE OF THE ATTORNEY
GENERAL
P.O. Box 12548, Capitol Station
Austin, Texas 78711
*ATTORNEY OF RECORD (512) 463-2080
(512) 936-2109

ATTORNEYS FOR DEFENDANT-APPELLANT

TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

Appellees State of Texas and Bryan Collier, submit this Motion for Extension of

Time to File their Brief. In support of this motion, Appellees offer the following:

1
Appellees’ brief is presently due on December 9, 2025. Appellees request the

Court grant them a thirty (30) day extension of time―until January 8, 2025―in which

to file the responsive briefs in this matter. Due to clerical error, AAG Perkins was made

aware of Appellant’s brief with around only one week to respond. Additionally, AAG

Perkins has four Motions for Summary Judgment due within nine days of each other.

AAG Kyle Perkins will need time to prepare a responsive brief.

This is Appellees’ first request for an extension. Good cause exists for the

granting of this Motion, which is not being presented for purposes of delay, nor for

purposes of prejudicing Appellant in prosecuting his 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

BRIANA M. WEBB
Division Chief, Law Enforcement Defense
Division

/s/ Kyle A. Perkins
KYLE A. PERKINS
Assistant Attorney General
Texas State Bar No. 24144087

2
Kyle.Perkins @oag.texas.gov
Law Enforcement Defense Division
OFFICE OF THE ATTORNEY GENERAL
P.O. Box 12548
Austin, TX 78711-2548
(512) 463-2080 / Fax: (512) 370-9323

ATTORNEYS FOR
DEFENDANTS-APPELLEES

CERTIFICATE OF CONFERENCE

I, KYLE A. PERKINS, Assistant Attorney General of Texas, do hereby certify

that due to the incarcerated status of Appellant, conference was not had. Appellees

assume that Appellant is opposed.

/s/ Kyle A. Perkins___
KYLE A. PERKINS
Assistant Attorney General

3
CERTIFICATE OF SERVICE

I, KYLE A. PERKINS, Assistant Attorney General of Texas, do hereby certify

that a true and correct copy of the above and foregoing Motion for Extension has

been served via the Court’s electronic case filing service within one business day of

December 9, 2025, on the following:

John Eric Anderson TDCJ #00552116 CMRRR 7021 2720 0002 0444 0063
TDCJ – LeBlanc Unit
3695 FM 3514
Beaumont, TX 77705
PLAINTIFF PRO SE

/s/ Kyle A. Perkins______
KYLE A. PERKINS
Assistant Attorney General

4
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.

Gloriana Ojeda on behalf of Kyle Perkins
Bar No. 24144087
gloriana.ojeda@oag.texas.gov
Envelope ID: 108912319
Filing Code Description: Motion
Filing Description: Anderson Appellee Motion for Extension of Time
Status as of 12/10/2025 7:13 AM CST

Associated Case Party: State of Texas, et al.

Name BarNumber Email TimestampSubmitted Status

Kyle Perkins 24144087 Kyle.Perkins@oag.texas.gov 12/9/2025 6:10:52 PM SENT

Daniel Rosales daniel.rosales@oag.texas.gov 12/9/2025 6:10:52 PM SENT