Texas Racing Commission v. Toby Keeton

ACCEPTED
15-25-00156-cv
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
11/17/2025 3:27 PM
No. 15-25-00156-CV CHRISTOPHER A. PRINE
CLERK
FILED IN
In the Fifteenth District Court of Appeals, Austin, TexasOF APPEALS
15th COURT
AUSTIN, TEXAS
11/17/2025 3:27:36 PM

TEXAS RACING COMMISSION, CHRISTOPHER A. PRINE
Clerk
Appellant,
v.

TOBY KEETON,
Appellee.

On Appeal from the 353rd District Court of Travis County, Texas
The Honorable Aurora Martinez-Jones, Presiding

UNOPPOSED MOTION FOR EXTENSION OF TIME FOR APPELLANT’S
BRIEF

Appellant, the Texas Racing Commission, respectfully requests an

18-day extension of time to December 15, 2025, in which to file its brief

in the captioned appeal. Appellee is unopposed to this motion. In support,

Appellant would show the Court as follows:

1. This is Appellant’s first request for an extension.

2. Appellant’s brief is due 20 days after both the court reporter’s and

clerk’s records are filed.

3. The clerk’s record was filed on November 4, 2025, and the reporter’s

record was filed on November 6, 2025.
4. Appellant’s brief is due on November 26, 2025.

5. This extension would make Appellant’s brief due Monday,

December 15, 2025.

6. Appellant has been inundated with multiple emergency cases,

which require immediate attention.

7. Additionally, the Office of the Attorney General has minimal staff

working or is closed from November 25-30, 2025.

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

allow Appellant’s counsel the time to adequately prepare and file its brief,

and to maintain consistent briefing schedules.

9. Counsel for Appellee is not opposed to this motion.

Appellant, the Texas Racing Commission, therefore, respectfully

requests an extension of time to and including December 15, 2025, in

which Appellant is to file and serve its brief in the captioned appeal.

UNOPPOSED MOTION FOR EXTENSION OF TIME
Case No. 15-25-00156-CV Page 2 of 4
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/ Lauren E. McGee
LAUREN E. MCGEE
State Bar No. 24128835
Assistant Attorney General
Administrative Law Division
Office of the Attorney General of Texas
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Telephone: (512) 475-3203
Lauren.McGee@oag.texas.gov

ATTORNEYS FOR APPELLANT TEXAS RACING
COMMISSION

UNOPPOSED MOTION FOR EXTENSION OF TIME
Case No. 15-25-00156-CV Page 3 of 4
CERTIFICATE OF CONFERENCE

I hereby certify that on November 13, 2025, counsel for all parties
conferred via email about the contents of this Motion and are unopposed
to the extensions being sought within the Motion.

/s/ Lauren McGee
LAUREN MCGEE
Assistant Attorney General

CERTIFICATE OF SERVICE

I hereby certify that on November 17, 2025, a true and correct copy
of the above and foregoing document has been served to the following
party of record via electronic service and/or electronic mail:

CLARK O. BREWSTER DON GRIFFIN, JR.
State Bar No. 786841 State Bar No. 08456975
JOSEPH C. DE ANGELIS Vinson & Elkins, LLP
Admitted Pro Hac Vice 845 Texas St., Ste 4700
Brewster & De Angelis, PLLC Houston, TX 77002-2946
2617 E. 21st Street Telephone: (713) 758-3508
Tulsa, OK 74114 dgriffin@velaw.com
Telephone: (918) 742-2021
cbrewster@brewsterlaw.com
jcdeangelis@brewsterlaw.com

ATTORNEYS FOR APPELLEE
TOBY KEETON

/s/ Lauren McGee
Lauren McGee
Assistant Attorney General

UNOPPOSED MOTION FOR EXTENSION OF TIME
Case No. 15-25-00156-CV Page 4 of 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.

Jennifer Foster on behalf of Lauren McGee
Bar No. 24128835
jennifer.foster@oag.texas.gov
Envelope ID: 108135083
Filing Code Description: Motion
Filing Description: Motion for Extension
Status as of 11/17/2025 3:35 PM CST

Associated Case Party: Toby Keeton

Name BarNumber Email TimestampSubmitted Status

Clark Brewster 786841 cbrewster@brewsterlaw.com 11/17/2025 3:27:36 PM SENT

Don Griffin 8456975 dgriffin@velaw.com 11/17/2025 3:27:36 PM SENT

Joseph DeAngelis jcdeangelis@brewsterlaw.com 11/17/2025 3:27:36 PM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Jennifer Foster Jennifer.Foster@oag.texas.gov 11/17/2025 3:27:36 PM SENT

Associated Case Party: Texas Racing Commission

Name BarNumber Email TimestampSubmitted Status

Lauren McGee lauren.mcgee@oag.texas.gov 11/17/2025 3:27:36 PM SENT