ACCEPTED
03-15-00078-CV
5432033
THIRD COURT OF APPEALS
AUSTIN, TEXAS
5/27/2015 12:24:15 PM
JEFFREY D. KYLE
CLERK
No. 03-15-00078-CV FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
IN THE
5/27/2015 12:24:15 PM
THIRD COURT OF APPEALS JEFFREY D. KYLE
AUSTIN, TEXAS Clerk
____________________________________________________________
CHRIS BELL,
Appellant
V.
REPUBLICAN GOVERNORS ASSOCIATION,
Appellee
_____________________________________________________________
ON APPEAL FROM THE
261ST JUDICIAL DISTRICT COURT,
TRAVIS COUNTY, TEXAS
______________________________________________________________
APPELLANT’S UNOPPOSED MOTION TO EXTEND TIME TO FILE
REPLY BRIEF
______________________________________________________________
TO THE HONORABLE THIRD COURT OF APPEALS:
Appellant, Chris Bell, files this Unopposed Motion to Extend Time to File
Reply Brief and in support would respectfully show as follows:
1. Appellant’s reply brief is currently due on June 1, 2015.
2. Appellant requests an additional fourteen (14) days to file his reply
brief, extending the time to June 15, 2015.
3. Appellant needs additional time to file his reply brief because the
undersigned has a brief due in this Court on June 5, 2015, in Case No. 03-15-
AUS-6110664-1 523389/1
00259-CV, styled Becky, Ltd. v. The City of Cedar Park, et al. In addition, the
parties are engaged in settlement negotiations.
4. This request is not for purpose of delay, but so that justice may be
done and this Court may be fully informed of all factual and legal information
relevant to the proper disposition of this appeal.
WHEREFORE, PREMISES CONSIDERED, Appellant requests that this
Court grant his Motion for Extension of Time to File Reply Brief on or before June
15, 2015.
Respectfully submitted,
HUSCH BLACKWELL LLP
By /s/ Elizabeth G. Bloch
ELIZABETH G. BLOCH
State Bar No. 02495500
Heidi.bloch@huschblackwell.com
THOMAS H. WATKINS
State Bar No. 20928000
Tom.Watkins@huschblackwell.com
111 Congress Avenue, Suite 1400
Austin, Texas 78701-4093
(512) 472-5456 (Telephone)
(512) 479-1101 (Facsimile)
ATTORNEYS FOR APPELLANT
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CERTIFICATE OF CONFERENCE
The undersigned certifies that she has consulted with Terry Scarborough,
counsel for Appellee, and he has indicated that Appellee is not opposed to this
motion.
/s/ Elizabeth G. Bloch
ELIZABETH G. BLOCH
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document
was served on the 27th day of May, 2015, via the Court’s electronic filing
system and/or facsimile to the following:
Terry L. Scarborough (512) 482-6891 (fax)
Hance Scarborough, LLP
111 Congress Ave., Suite 500
Austin, Texas 78701
/s/ Elizabeth G. Bloch
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