Becky, Ltd. v. the City of Cedar Park, Matt Powell, Stephen Thomas, Lyle Grimes, Lowell Moore, Jon Lux, and Don Tracy

ACCEPTED
03-15-00259-CV
5559956
THIRD COURT OF APPEALS
AUSTIN, TEXAS
6/5/2015 10:53:38 AM
JEFFREY D. KYLE
CLERK

No. 03-15-00259-CV FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
IN THE 6/5/2015 10:53:38 AM
THIRD COURT OF APPEALS JEFFREY D. KYLE
AUSTIN, TEXAS Clerk
____________________________________________________________

BECKY, LTD.,
Appellant

V.
THE CITY OF CEDAR PARK, STEPHEN THOMAS, MATT POWELL, MITCH
FULLER, LYLE GRIMES, LOWELL MOORE, JON LUX, AND DON TRACY,
Appellees
_____________________________________________________________

ON APPEAL FROM THE
126TH JUDICIAL DISTRICT COURT,
TRAVIS COUNTY, TEXAS
______________________________________________________________

APPELLANT’S UNOPPOSED MOTION TO
EXTEND TIME TO FILE BRIEF
______________________________________________________________

TO THE HONORABLE THIRD COURT OF APPEALS:

Appellant, Becky, Ltd., files this Unopposed Motion to Extend Time to File

Brief and in support would respectfully show as follows:

1. Appellant’s brief is currently due on June 5, 2015.

2. Appellant requests an additional seven (7) days to file its brief,

extending the time to June 12, 2015.

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 3. Appellant needs additional time to file its brief because the Appellant

has requested preparation of a supplemental clerk’s record, which should be filed

shortly. In addition, the undersigned has been working on a petition for review

filed with the Texas Supreme Court on May 18, 2015, in Case No. 15-0373,

Malouf v. State of Texas, and preparing for a hearing before the State Office of

Hearings and Appeals on June 2, 2015, in PUCT Docket Numbers 44547 and

44649.

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 its Motion for Extension of Time to File Brief on or before June 12,

2015.

Respectfully submitted,

HUSCH BLACKWELL LLP

By /s/ Elizabeth G. Bloch
ELIZABETH G. BLOCH
State Bar No. 02495500
Heidi.bloch@huschblackwell.com
111 Congress Avenue, Suite 1400
Austin, Texas 78701-4093
(512) 472-5456 (Telephone)
(512) 479-1101 (Facsimile)

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 Leonard B. Smith
State Bar No. 18643100
lsmith@leonardsmithlaw.com
P.O. Box 684633
Austin, Texas 78768
(512) 914-3732 (Telephone)
(512) 532-6446 (Facsimile)

ATTORNEYS FOR APPELLANT

CERTIFICATE OF CONFERENCE
The undersigned certifies that she has consulted via email with counsel for
Appellees the City of Cedar Park and the individual Appellees, and they have
indicated that they do not oppose 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 5th day of June, 2015, via the Court’s electronic filing
system and/or email to the following counsel of record:

Cobby Caputo
ccaputo@bickerstaff.com
Bradley B. Young
byoung@bickerstaff.com
Bickerstaff Heath Delgado Acosta LLP
3711 South MoPac Expressway
Building One, Suite 300
Austin, Texas 78746

/s/ Elizabeth G. Bloch

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