Chris Bell v. Republican Governors Association

ACCEPTED
03-15-00078-CV
4960128
THIRD COURT OF APPEALS
AUSTIN, TEXAS
April 20, 2015 4/20/2015 4:44:55 PM
JEFFREY D. KYLE
CLERK
NO. 03-15-00078-CV

IN THE COURT OF APPEALS
FOR THE THIRD DISTRICT OF TEXAS,
AT AUSTIN, TEXAS

CHRIS BELL,
Appellant,
v.
REPUBLICAN GOVERNORS ASSOCIATION
Appellee

From 261st District Court,
Travis County, Texas

UNOPPOSED FIRST MOTION TO EXTEND TIME TO
FILE APPELLEE'S BRIEF

TO THE HONORABLE THIRD COURT OF APPEALS:

Pursuant to TEX. R. APP. P. 10.1 and 38.6(d), Appellee Republican

Governors Association files this Unopposed First Motion to Extend Time to File

Appellee's Brief, and would respectfully show as follows:

1. Appellee's response brief is currently due on April27, 2015.

2. Counsel for Appellee requests a 14-day extension of time to file its

brief, making the brief due on May 11, 2015. This is the first request for extension

of time to file the response brief.
 3. Counsel for Appellee relies on the following reasons, in addition to

the routine matters that counsel must attend to in daily practice, to explain the need

for the requested extension:

1. Counsel's litigation and appellate practice consists of two

attorneys. Currently, one of said attorneys is out on maternity leave, which

in-tum limits the amount of time available to counsel to draft its response

brief and attend to the other matters for which it is responsible. Several of

Counsel's other matters require immediate attention this week, further

limiting the time available to Counsel to draft its response brief.

4. Therefore, Counsel for Appellee seeks this extension of time to be

able to prepare a cogent and succinct brief to aid this Court in its analysis of the

issues presented. This request is not sought for delay but so that justice may be

done.

5. The undersigned has conferred with opposing counsel, and he has

indicated that his client does not oppose this motion.

6. All facts recited in this motion are within the personal knowledge of

the counsel signing this motion, therefore no verification is necessary under Rule

of Appellate Procedure 10.2.
-------------------- ------------- --------------------

PRAYER FOR RELIEF

For the reasons set forth above, Appellee requests that this Court grant this

Unopposed First Motion to Extend Time to File Appellee's Response Brief and

extend the Deadline for Filing the Appellee's Response Brief to May 11, 2015.

Respectfully submitted,

Respectfully submitted,

HANCESCARBOROUGH,LLP
400 W. 15th Street, Suite 950
Austin, Texas 78701
Telephone: (512) 479-8888
Facsimile: (512) 482-6891

carborough
State ar No. 17716000
V. Blayre Pefia
State Bar No. 24050372

ATTORNEYS FOR DEFENDANT
REPUBLICAN GOVENORS ASSOCIATION
 -------------------

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document has
been forwarded to all counsel of record herein by facsimile on this the 20th day of
April, 20 15.

VIA FACSIMILE
Tom H. Watkins
Rusch Blackwell
111 Congress Avenue, Suite 1400
Austin, Texas 78701-4093
Telephone: (512) 703-5752
Facsimile: (512) 479-1101

Randall B. Wood
RAY, WOOD&BONILLA
2700 Bee Caves Road, Suite 200
Austin, Texas 78746
Telephone: (512) 328-8877
Facsimile: (512) 328-1156