Glenn Hegar, Comptroller of Public Accounts of the State of Texas, and Ken Paxton, Attorney General of the State of Texas v. CGG Veritas Services (U.S.), Inc.

ACCEPTED
03-14-00713-CV
4886053
THIRD COURT OF APPEALS
AUSTIN, TEXAS
4/14/2015 3:41:21 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
4/14/2015 3:41:21 PM
JEFFREY D. KYLE
Austin, Texas Clerk

GLENN HEGAR, COMPTROLLER OF PUBLIC ACCOUNTS OF THE STATE OF TEXAS, AND
KEN PAXTON, 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 THIRD 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 Glenn Hegar, 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. Appellee does not oppose motion.

Appellants’ brief is currently due on April 15, 2015. Appellants seek a 6-day

extension, which would make its brief due on April 20, 2015. Two previous extensions

have been granted.
Appellants seek an extension due to counsel’s workload commitments, and not

for purposes of delay. Appellants’ counsel requests a six-day extension due to the

scheduling of a hearing in a different case. The Fifth Circuit has set a hearing on the

United States of America’s motion for stay pending appeal in Case No. 15-40238, State

of Texas, et al. v. United States of America, et al. (5th Cir. 2015). The hearing will take place

on April 17, 2015. Each side has been granted an hour for argument in that case.

Due to the commitments involved in traveling and preparing lead counsel for

that hearing, additional time is requested for Appellants’ counsel to facilitate finalizing

and filing of Appellants’ brief in this case.

II.

For this reason, counsel for Appellants respectfully requests that the deadline to

file Appellants’ brief be extended to April 20, 2015.

2
PRAYER

Appellants respectfully requests that the Court grant it a 6-day extension of time

to file its brief, making that brief due on April 20, 2015.

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

3
CERTIFICATE OF CONFERENCE

I hereby certify that on April 14, 2015 I contacted counsel for Appellee. 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 April 14, 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