Raghunath Dass, P.E. v. Texas Board of Professional Engineers

ACCEPTED
03-14-00552-CV
3709269
THIRD COURT OF APPEALS
AUSTIN, TEXAS
1/9/2015 10:31:18 AM
JEFFREY D. KYLE
CLERK
No. 03-14-00552-CV
RAGHUNATH DASS, P. E., ˜ IN THE THIRD
Appellant, ˜ FILED IN
˜ 3rd COURT OF APPEALS
AUSTIN, TEXAS
v. ˜ COURT OF APPEALS
1/9/2015 10:31:18 AM
˜
TEXAS BOARD OF ˜ JEFFREY D. KYLE
Clerk
PROFESSIONAL ENGINEERS ˜ AUSTIN, TEXAS
Appellee. ˜

APPELLANT’S SECOND UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF

Appellant asks the Court to extend the time to file his brief.
A. INTRODUCTION
1. Appellant is Raghunath Dass, P.E.; appellee is the Texas Board of Professional Engineers.
2. There is no specific deadline to file this motion to extend time. See Tex. R. App. P. 38.6(d).
3. Appellant’s counsel has conferred with Appellee’s counsel, who stated that she is unopposed
to this motion and the proposed new time to file brief for Appellant.
B. ARGUMENT & AUTHORITIES
4. The Court has the authority under Texas Rule of Appellate Procedure 38.6(d) to extend the
time to file a brief.
5. Appellant’s brief is due on January 16, 2015.
6. Appellant requests an additional 14 days to file his brief, extending the time until January
30, 2015.
7. One previous extension has been granted to extend the time to file Appellant’s brief.
8. Appellant needs additional time to file his brief because attorneys for both parties have
consulted and agreed to change the scope of the issues addressed.
C. CONCLUSION
10. Appellant is requesting an extension of time to file his brief so that the scope of both briefs
can be adjusted in accordance with the informal agreement between the parties. Appellant believes
that an extension of time to file his brief until January 30, 2015 will be sufficient to allow both
parties to make the necessary revisions.

APPELLANT’S SECOND UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF Page 1 of 3
 D. PRAYER
11. For these reasons, Appellant asks the Court to grant an extension of time to file his brief until
January 30, 2015.
Respectfully submitted,

JIMMY ALAN HALL, PLLC
4600 Mueller Boulevard, Suite 2121
Austin, Texas 78723-3294
Telephone: 512-722-3190
Telecopier: 512-857-9195
jahall@fbjah.com

State Bar No.08759800

ATTORNEY FOR APPELLANT

APPELLANT’S SECOND UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF Page 2 of 3
 CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing Appellant’s Second Unopposed
Motion to Extend Time to File Brief has been sent in accordance with the Texas Rules of Appellate
Procedure, as noted below, on this 9th day of January, 2015, to:

Jennifer L. Hopgood
Assistant Attorney General
Administrative Law Division
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Telephone: (512) 936-1660
Facsimile: (512) 320-0167
jennifer.hopgood@texasattorneygeneral.gov
G Hand Delivery in Person or by Agent G Courier Receipted Delivery G Telephonic Document Transfer O eService

APPELLANT’S SECOND UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF Page 3 of 3