Texas Quarter Horse Association Texas Thoroughbred Association Texas Horsemen's Partnership Gillespie County Fair and Festivals Association, Inc.et Al. // American Legion Department of Texas v. American Legion Department of Texas, Temple Post 133 Kickapoo Traditional Tribe of Texas Thompson Allstate Bingo Supply, Inc. And Moore Supplies, Inc.// Texas Quarter Horse

Summarize
Check Treatment

Related Cases

ACCEPTED 03-15-00118-CV 5276893 THIRD COURT OF APPEALS AUSTIN, TEXAS 5/14/2015 7:10:30 AM JEFFREY D. KYLE CLERK No. 03-15-00118-CV _______________________________________ FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS IN THE COURT OF APPEALS 5/14/2015 7:10:30 AM FOR THE THIRD DISTRICT OF TEXAS JEFFREY D. KYLE AUSTIN, TEXAS Clerk _______________________________________ TEXAS QUARTER HORSE ASSOCIATION; TEXAS THOROUGHBRED ASSOCIATION; TEXAS HORSEMEN’S PARTNERSHIP; GILLESPIE COUNTY FAIR AND FESTIVALS ASSOCIATION, INC.; GLOBAL GAMING LSP, LLC d/b/a LONE STAR PARK AT GRAND PRAIRIE; and SAM HOUSTON RACE PARK, LLC, Appellants v. AMERICAN LEGION DEPARTMENT OF TEXAS, TEMPLE POST 133; KICKAPOO TRADITIONAL TRIBE OF TEXAS; THOMPSON ALLSTATE BINGO SUPPLY, INC.; and MOORE SUPPLIES, INC., Appellees __________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO APPELLEES’ MOTION TO DISMISS _________________________________________________ Pursuant to Tex. R. App. P. 10.1 and 10.5(b), Appellants herein, file this unopposed motion for a 30-day extension of time in which to file their response to Appellees’ motion to dismiss. Appellants ask this Court to extend the deadline for filing their response to Appellees’ motion to dismiss from May 18, 2015, through and until June 17, 2015. In support of this requested extension, Appellants would show the following: 1 1. The current deadline for filing Appellants’ response to Appellees’ motion to dismiss is May 18, 2015. 2. Appellants request a 30-day extension of time in which to file their response to Appellees’ motion to dismiss because Appellees’ motion raises new issues that previously have not been argued in this case. Additionally, time is needed to coordinate among the multiple Appellants and their counsel. 3. Appellants respectfully ask that their request for a 30-day extension be granted so they will have sufficient time to prepare a response to Appellees’ motion to dismiss that is comprehensive, concise, and useful to this Court’s consideration. 4. This is Appellants’ first request for an extension to file their response to Appellees’ motion to dismiss. 5. Appellees do not oppose the granting of the motion for extension. WHEREFORE, Appellants pray that this Court grant their unopposed motion for an extension of time in which to file their response to Appellees’ motion to dismiss and extend the deadline for filing the response from May 18, 2015, through and until June 17, 2015. Appellants also request such other and further relief to which they may be entitled. 2 DATED: May 14, 2015 Respectfully submitted, By: /s/ J. Bruce Bennett J. Bruce Bennett Martha S. Dickie, J. Bruce Bennett State Bar No. 00000081 State Bar No. 02145500 Boone Almanza John A. Cardwell State Bar No. 01579001 State Bar No. 03791200 ALMANZA, BLACKBURN & DICKIE, LLP CARDWELL, HART & BENNETT, LLP 2301 South Capital of Texas Highway, 807 Brazos, Suite 1001 Building H Austin, Texas 78701 Austin, Texas 78746 Tel: (512) 322-0011 Tel: (512) 478-9486 Fax: (512) 322-0808 Fax: (512) 478-7151 cardwell53@earthlink.net mdickie@abdlawfirm.com jbb.chblaw@me.com balmanza@abdlawfirm.com --and-- COUNSEL FOR APPELLANT GILLESPIE Dudley D. McCalla COUNTY FAIR AND FESTIVALS State Bar No. 13354000 ASSOCIATION, INC. JACKSON WALKER, LLP 100 Congress Avenue Ste 1100 Austin, Texas 78701-0000 James C. Ho Tel: (512) 236-2071 State Bar No. 24052766 Fax: (512) 236-2002 Bradley G. Hubbard dmccalla@jw.com State Bar No. 24090174 GIBSON, DUNN & CRUTCHER LLP COUNSEL FOR APPELLANT GLOBAL GAMING 2100 McKinney Avenue, Suite 1100 LSP, LLC D/B/A LONE STAR PARK AT Dallas, Texas 75201 GRAND PRAIRIE Tel: (214) 698-3100 Fax: (214) 571-2934 jho@gibsondunn.com Robert G. Hargrove bhubbard@gibsondunn.com State Bar No. 24032391 Ana Maria Marsland Griffith COUNSEL FOR APPELLANT SAM State Bar No. 13049300 HOUSTON RACE PARK, LLC OSBORN, GRIFFITH & HARGROVE 515 Congress Ave., Suite 2450 3 Austin, Texas 78701 Tel: (512) 476-3529 Fax: (512) 476-8310 rob@texasenergylaw.com anamaria@texasenergylaw.com COUNSEL FOR APPELLANTS TEXAS QUARTER HORSE ASSOCIATION, TEXAS THOROUGHBRED ASSOCIATION, AND TEXAS HORSEMEN’S PARTNERSHIP CERTIFICATE OF CONFERENCE I hereby certify that I have conferred with Mr. Raymond White, counsel for Appellees, regarding this Motion. Appellees do not oppose the granting of the relief sought. /s/ J. Bruce Bennett J. Bruce Bennett CERTIFICATE OF SERVICE I certify that a true copy of foregoing Motion was served via electronic means on all counsel of record in this case on this 14th day of May 2015: /s/ J. Bruce Bennett J. Bruce Bennett 4