ACCEPTED
03-14-00713-CV
4081063
THIRD COURT OF APPEALS
AUSTIN, TEXAS
2/9/2015 5:06:23 PM
JEFFREY D. KYLE
CLERK
No. 03-14-00713-CV
In The Court of Appeals 3rd COURTFILED IN
OF APPEALS
AUSTIN, TEXAS
For the Third Judicial District
2/9/2015 5:06:23 PM
JEFFREY D. KYLE
Austin, Texas Clerk
SUSAN COMBS, COMPTROLLER OF PUBLIC ACCOUNTS OF THE STATE OF TEXAS, AND
GREG ABBOTT, ATTORNEY GENERAL OF THE STATE OF TEXAS,
Appellants,
v.
CGG VERITAS SERVICES (U.S.), INC.,
Appellee.
On Appeal from the
353rd Judicial District Court of Travis County, Texas
APPELLANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME
TO THE HONORABLE THIRD COURT OF APPEALS:
In accordance with Texas Rules of Appellate Procedure 10.5(b) and 38.6(d),
Appellants Susan Combs, Comptroller of Public Accounts of the State of Texas, and
Ken Paxton, Attorney General of the State of Texas, move for an extension of time
to file its brief. Appellees do not oppose motion.
I.
Appellants’ brief is currently due on February 12, 2015. Appellants seek a 30-
day extension, which would make its brief due on or before Monday, March 16, 2015.
No previous extensions have been requested.
First, Appellants are represented by new lead counsel in this Court. Appellants’
new counsel on appeal requires time to review the record and research the legal issues
prior to preparing and filing the petition for review.
Second, Appellants’ new lead counsel has and will continue to have a
significant workload in other matters that will make it impossible to complete by the
current deadline a response to the petition that will be helpful to the Court. That
workload includes reviewing the record and
• drafting a petition for review in Texas Health and Human Services
Commission and Officer of the Inspector General v. Harlingen Family Dentistry,
P.C., No. -------, in the Texas Supreme Court
• drafting a motion to affirm in response to a statement of jurisdiction in
Evenewel v. Abbott, No. 14-940, in the U.S. Supreme Court, and
• ongoing responsibilities in Escamilla v. Stephens, No. 12-70029, a capital
habeas case in the U.S. Court of Appeals for the Fifth Circuit.
II.
For each of these reasons, counsel for the Appellants requests additional time
to review the record on appeal and analyze the relevant law so as to provide the Court
with a thorough and helpful brief.
PRAYER
Appellants respectfully requests that the Court grant it a 30-day extension of
time to file its brief, making that brief due on March 16, 2015.
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Respectfully submitted.
KEN PAXTON
Attorney General of Texas
CHARLES E. ROY
First Assistant Attorney General
SCOTT A. KELLER
Solicitor General
/s/ April L. Farris
APRIL L. FARRIS
Assistant Solicitor General
State Bar No. 24069702
OFFICE OF THE ATTORNEY GENERAL
P.O. Box 12548 (MC 059)
Austin, Texas 78711-2548
Tel.: (512) 936-2923
Fax: (512) 474-2697
april.farris@texasattorneygeneral.gov
COUNSEL FOR APPELLANTS
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CERTIFICATE OF CONFERENCE
I hereby certify that on February 6, 2015 I contacted counsel for Appellees
Counsel does not oppose this motion.
/s/ April L. Farris
April L. Farris
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document has
been electronically filed and served via File&ServeXpress on February 9, 2015, to the
following:
Amanda Taylor
State Bar No. 24045921
James F. Martens
State Bar No. 13050720
Lacy Leonard
State Bar No. 24040561
MARTENS TODD LEONARD & TAYLOR
301 Congress Ave., Suite 1950
Austin, Texas 78701
Tel.: (512) 542-9898
Fax: (512) 542-9899
ataylor@textaxlaw.com
jmartens@textaxlaw.com
lleonard@textaxlaw.com
Counsel for Appellee
/s/ April L. Farris
April L. Farris
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