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CAUSE NO.

D-1-GN-15-004336

GRASSROOTS LEADERSHIP, INC.,


et. al.,

Plaintiffs,

v.

TEXAS DEPARTMENT OF FAMILY


AND PROTECTIVE SERVICES, et al.,
Defendants.

IN THE DISTRICT COURT OF

TRAVIS COUNTY, TEXAS

353RD JUDICIAL DISTRICT

DEFENDANTS NOTICE OF APPEAL


Defendants, the Texas Department of Family and Protective Services (DFPS);
Henry Whitman, in his official capacity as DFPS Commissioner; Texas Health and Human
Services (HHSC); and Charles Smith, in his official capacity as HHSC Executive
Commissioner, hereby give notice of their desire to appeal the Courts orders signed on
December 2, 2016.
Defendants appeal to the Third Court of Appeals.
Dated: December 5, 2016.
Respectfully submitted,
KEN PAXTON
Attorney General of Texas
JEFFREY C. MATEER
First Assistant Attorney General
JAMES E. DAVIS
Deputy Attorney General for Civil Litigation

/s/ Todd Lawrence Disher


TODD LAWRENCE DISHER
Assistant Attorney General
State Bar No. 24081854
Office of the Attorney General of Texas
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Telephone: (512) 936-2266
Facsimile: (512) 936-0545
todd.disher@texasattorneygeneral.gov
NICHOLE BUNKER-HENDERSON
Chief, Administrative Law Division
Assistant Attorney General
State Bar No. 24045580
Office of the Attorney General of Texas
Administrative Law Division
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Telephone: (512) 936-0804
Facsimile: (512) 320-0167
nichole.bunker-henderson@texasattorneygeneral.gov
Attorneys for Defendants

CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document was served
on the 5th day of December 2016 on the following via e-serve and/or e-mail:
Jerome Wesevich
Robert Doggett
Texas RioGrande Legal Aid, Inc.
4920 North IH 35
Austin, Texas 78751
jwesevich@trla.org
rdoggett@trla.org
Attorneys for Plaintiff
Charles A. Deacon
Bertina B. York
300 Convent Street, Suite 2100
San Antonio, Texas 78205
charlie.deacon@nortonrosefulbright.com
bertina.york@nortonrosefulbright.com
Attorneys for Intervenor,
The GEO Group
Jay W. Brown
Andrew L. Edelman
Bruce R. Wilkin
1100 JP Morgan Chase Tower
600 Travis Street
Houston, Texas 77002
jbrown@winstead.com
aedeleman@winstead.com
bwilkin@winstead.com
Attorneys for Intervenor,
Corrections Corporation of America

/s/ Todd Lawrence Disher


TODD LAWRENCE DISHER
Assistant Attorney General
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