Texas Department of Insurance and Cassie Brown, in Her Capacity as Commissioner of the Texas Department of Insurance v. Texas Land Title Association

ACCEPTED
15-25-00107-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
10/15/2025 1:45 PM
No. 15-25-00107-CV CHRISTOPHER A. PRINE
CLERK
FILED IN
15th COURT OF APPEALS
IN THE FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS
AUSTIN, TEXAS 10/15/2025 1:45:14 PM
CHRISTOPHER A. PRINE
Clerk

TEXAS DEPARTMENT OF INSURANCE, AND CASSIE BROWN, IN HER CAPACITY AS
COMMISSIONER OF THE TEXAS DEPARTMENT OF INSURANCE,

Appellants,

v.

TEXAS LAND TITLE ASSOCIATION,

Appellee.

On Appeal from the 345th Judicial District Court
Travis County, Texas
Cause No. D-1-GN-25-001663

JOINT MOTION TO EXTEND TIME FOR FILING OF
APPELLEE’S BRIEF

Appellants, The Texas Department of Insurance and Cassie Brown, In Her

Capacity As Commissioner of the Texas Department of Insurance, and Appellee,

Texas Land Title Association file this joint motion for extension of deadline to file

Appellee’s brief on the grounds set forth below:

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I.

This case involves a challenge to a ratemaking order pertaining to title

insurance. A new ratemaking process is under way at the Texas Department of

Insurance, and this process may well result in mooting this appeal and the underlying

litigation by the end of the year. However, in the meantime, Appellee’s brief is due

on November 10, 2025. In order to let the new ratemaking process play out, and to

conserve both judicial resources and those of the parties, Appellants and Appellee

hereby request a 60-day extension on the deadline to file Appellee’s brief.

Pursuant to Tex. R. App. P. 10.5(b), the parties state the following: (1) The

current deadline for Appellee’s Brief is November 10, 2025, which is 60 days after

the original deadline of September 10, 2025; (2) the parties to this appeal are

requesting another 60-day extension, until January 9, 2026; (3) the requested

extension, which is made jointly, is to allow a new ratemaking process to play out

which may moot this appeal and the underlying litigation; and (4) one previous

unopposed 60-day extension was requested and granted by the Court.

CONCLUSION OR PRAYER

For the reasons stated herein, Appellants and Appellee hereby requests a 60-

day extension of the deadline for filing Appellee’s Brief, making it due on January

9, 2026.

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Respectfully submitted,

By Ray Chester
Ray C. Chester
State Bar No. 04189065
Andrew M. Edge
State Bar No. 24071446
McGinnis Lochridge LLP
1111 W. 6th Street, Bldg. B,
Suite 400
Austin, Texas 78703
(512) 495-6000
(512) 495-6093 (Fax)
rchester@mcginnislaw.com
aedge@mcginnislaw.com
Attorneys for Appellee

By /s/ Rosalind L. Hunt with permission
Rosalind L. Hunt
State Bar No. 24067108
Assistant Attorney Generals
Administrative Law Division
Office of the Attorney General of
Texas
P. O. Box 12548, Capitol Station
Austin, Texas 78711-2548
(512) 475-4166
(512) 320-0167 (Fax)
Rosaline. Hunt@oag.texas.gov

Attorneys for Appellants
Texas Department of Insurance
And Commissioner Cassie
Brown

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CERTIFICATE OF CONFERENCE

I hereby certify that pursuant to Tex. R. App. P. 10.1(5), on the 15th day of

October, 2025, I conferred with Rosalind Hunt, lead appellate counsel for

Appellants, and Appellants join in this motion.

Ray Chester

CERTIFICATE OF SERVICE

I hereby certify that on the 15th day of October, 2025, I electronically filed

the above and foregoing document, which will send notification of such filing to:

ROSALIND L. HUNT
State Bar No. 24067108
Assistant Attorney Generals
Administrative Law Division
Office of the Attorney General of Texas
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Telephone: (512) 475-4166
Facsimile: (512) 320-0167
Rosalind.Hunt@oag.texas.gov

Ray Chester

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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.

Kim McBride on behalf of Ray Chester
Bar No. 04189065
kmcbride@mcginnislaw.com
Envelope ID: 106878395
Filing Code Description: Motion
Filing Description: Joint Motion to Extend Time for Filing of Appellee's
Brief
Status as of 10/15/2025 2:07 PM CST

Associated Case Party: Texas Land Title Association

Name BarNumber Email TimestampSubmitted Status

Kim McBride kmcbride@mcginnislaw.com 10/15/2025 1:45:14 PM SENT

Associated Case Party: Texas Department of Insurance

Name BarNumber Email TimestampSubmitted Status

Rosalind Hunt rosalind.hunt@oag.texas.gov 10/15/2025 1:45:14 PM SENT

Jennifer Foster Jennifer.Foster@oag.texas.gov 10/15/2025 1:45:14 PM SENT

Meridith Fischer Meridith.Fischer@oag.texas.gov 10/15/2025 1:45:14 PM SENT

John Grey John.Grey@oag.texas.gov 10/15/2025 1:45:14 PM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Ray Chester rchester@mcginnislaw.com 10/15/2025 1:45:14 PM SENT

Drew Edge aedge@mcginnislaw.com 10/15/2025 1:45:14 PM SENT

James Brazell James.Brazell@oag.texas.gov 10/15/2025 1:45:14 PM SENT