Board of Regents, Texas State University System, and Texas State University-San Marcos v. Stephanie Paige Steinbach

ACCEPTED
03-14-00326-CV
3655061
THIRD COURT OF APPEALS
AUSTIN, TEXAS
1/5/2015 4:18:00 PM
JEFFREY D. KYLE
CLERK
CAUSE NO. 03-14-00326-CV

FILED IN
3rd COURT OF APPEALS
BOARD OF REGENTS, TEXAS § IN THE COURT OF APPEALS
AUSTIN, TEXAS
STATE UNIVERSITY and § 1/5/2015 4:18:00 PM
TEXAS STATE UNIVERSITY - § JEFFREY D. KYLE
SAN MARCOS, § Clerk
Appellants, §
§
V. § THIRD DISTRICT OF TEXAS
§
STEPHANIE PAIGE STEINBACH §
Appellee. § AUSTIN DIVISION

UNOPPOSED SECOND MOTION FOR EXTENSION
OF TIME TO FILE APPELLANT’S REPLY BRIEF

TO THE HONORABLE COURT OF APPEALS:

COMES NOW Appellants Board of Regents, Texas State University and

Texas State University–San Marcos, by and through the undersigned Assistant

Attorney General, and files this its Unopposed First Motion for Extension of Time

to File Appellant’s Reply Brief; and would show the Court as follows:

1. Appellants are Board of Regents, Texas State University and Texas State

University–San Marcos. Appellee is Stephanie Paige Steinbach.

2. Appellants’ reply brief is currently due on January 9, 2015.

Cause No. 10-0281; Stephanie Steinbach vs. Board of Regents, Texas State University System and Texas State University - San Marcos
Unopposed Second Motion for Extension of Time to File Appellant’s Reply Brief Page No. 1
3. This Unopposed Second Motion to Extend Time is filed before the deadline

to file the reply brief. See Tex. R. App. P. 38.6(d).

4. Appellants have contacted attorney for Appellee, and he is unopposed to

this Motion.

5. Pursuant to Rules 10.5(b) and 38.6(d) of the Texas Rule of Appellate

Procedure, Appellants move this Court for a 30 day extension of time to file

Appellants’ brief, extending the deadline to February 9, 2015.

6. Appellants seek an extension of time to file their brief because counsel for

Appellants is leaving the Office of Attorney General effective January 9, 2015. In

addition, Appellants’ counsel was out of state over the holidays and was also out of

the office several days in December 2014 for medical reasons.

PRAYER

For these reasons, Appellants ask the Court to grant an extension of time to

file their reply brief, thereby extending the deadline to February 9, 2015.

Respectfully submitted,
KEN PAXTON
Attorney General of Texas

CHARLES E. ROY
First Assistant Attorney General
DAVID C. MATTAX
Deputy Attorney General for Defense Litigation

Cause No. 10-0281; Stephanie Steinbach vs. Board of Regents, Texas State University System and Texas State University - San Marcos
Unopposed Second Motion for Extension of Time to File Appellant’s Reply Brief Page No. 2
 KARA L. KENNEDY
Chief, Tort Litigation Division

/s/ Kamilla L. Stokes
KAMILLA L. STOKES
Assistant Attorney General
State Bar No. 00792259
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
(512) 463-2197
Fax (512) 457-4436
Kamilla.stokes@texasattorneygeneral.gov

CERTIFICATE OF CONFERENCE

I hereby certify that on the 5th day of January, 2015, I contacted Mark
Cusack, attorney for Appellee, and he is unopposed to this Second Motion for
Extension of Time to File Appellant’s Reply Brief.

/s/ Kamilla L. Stokes
KAMILLA L. STOKES
Assistant Attorney General

CERTIFICATE OF SERVICE

I do hereby certify compliance with Tex. R. Civ. P. 21. A true and correct
copy of the foregoing instrument has been served on all counsel, by electronic
transmission to the electronic mail address on file with the electronic filing manager
Rule 21a(1). If a party has not designated an electronic mail address with the
electronic filing manager, the party was served a true and correct copy of the
foregoing instrument in person, by mail, by commercial delivery service by fax or
by email, or by such other manner as the Court in its discretion may direct. Rule
21a(2). Service was made on all parties as provided on January 5, 2015.

Cause No. 10-0281; Stephanie Steinbach vs. Board of Regents, Texas State University System and Texas State University - San Marcos
Unopposed Second Motion for Extension of Time to File Appellant’s Reply Brief Page No. 3
Via Electronic Service & E-Mail
Mr. Mark Cusack
242 North Guadalupe Street
San Marcos, Texas 78666
cusacklaw@centurytel.net

/s/ Kamilla L. Stokes
KAMILLA L. STOKES
Assistant Attorney General

Cause No. 10-0281; Stephanie Steinbach vs. Board of Regents, Texas State University System and Texas State University - San Marcos
Unopposed Second Motion for Extension of Time to File Appellant’s Reply Brief Page No. 4