ACCEPTED
06-15-00078-cv
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
11/18/2015 9:25:13 AM
DEBBIE AUTREY
CLERK
NO. 6-15-00078-CV
______________________________________________
FILED IN
IN THE COURT OF APPEALS FOR THE 6th COURT OF APPEALS
SIXTH DISTRICT OF TEXAS AT TEXARKANA TEXARKANA, TEXAS
______________________________________________
11/18/2015 9:25:13 AM
DEBBIE AUTREY
TOCHRIL, INCORPORATED, Clerk
Appellants,
VS.
TEXAS WORKFORCE COMMISSION,
Appellee.
______________________________________________
ON APPEAL FROM 53rd JUDICIAL DISTRICT COURT OF
TRAVIS COUNTY, TEXAS
MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF
Appellant Tochril, Incorporated, doing business as Health Force (“Health Force”), files
this Motion For Extension of Time to File Appellant’s Brief pursuant to Rules 10.5 and
38.6(d) of the Texas Rules of Appellate Procedure.
By October 27, 2015 letter from the Court’s deputy clerk, the initial deadline for
Appellant to file its appellate brief is November 30, 2010 (the first business day after the
Thanksgiving holiday).
This is Appellants’ first request for an extension of time.
Appellant requests an extension of time until December 31, 2015 to file its brief.
This extension is sought for the following reasons:
1. Counsel for Appellant are set for an evidentiary administrative (“Rule 13”) hearing on
December 1, 2015 in ExTech Consulting, LLC, Tax Account No. 14-701499-6, Case
No. 15-096-6515;
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2. Counsel for Appellant are set for trial on December 9, 2015 in Civil Action No. 4:14-
cv-00274; Michele Spencer vs. KS Management Services, LLC; In the United States
District Court for the Southern District of Texas, Houston Division; and
3. Seven depositions are scheduled for December 7-18, 2015 in order to meet a January
4, 2016 discovery deadline in Civil Action No. 2:14-cv-00131; Zach Westbrook v.
Advanced Solids Control, LLC; In the United States District Court Southern District
of Texas Corpus Christi Division.
WHEREFORE, Appellant respectfully requests this Court grant its request for
extended time until December 31, 2015 to file its appellate brief.
Respectfully submitted,
CRAIN, CATON & JAMES, PC
By: s/ Juliann H. Panagos
JULIANN H. PANAGOS
State Bar No. 06861100
jpanagos@craincaton.com
MICHAEL D. SEALE
State Bar No. 00784938
mseale@craincaton.com
1401 McKinney Street, Suite 1700
Houston, Texas 77010
Telephone: 713-752-8696
Facsimile: 713-658-1921
ATTORNEYS FOR PLAINTIFF
TOCHRIL, INCORPORATED
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of Motion For Extension of Time to File
Appellant’s Brief has been forwarded to the following attorney in the manner stated on the 18th
day of November 2015:
VIA CERTIFIED MAIL / RETURN RECEIPT REQUESTED
E-MAIL: PETER.LAURIE@AOG.STATE.TX.US
Mr. Peter Laurie
Assistant Attorney General
Taxation Division
P.O. Box 12548
Austin, Texas 78711-2548
s/ Juliann H. Panagos
Juliann H. Panagos
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