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.
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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
Chris Bell v. Republican Governors Association
Combined Opinion